Patel v. Patel
Civil Action No. 2016-2411
| D.D.C. | Sep 19, 2017Background
- Plaintiff Kamal K. Patel, a U.K. resident, sued his relatives Vijaykant and Bhartiben Patel (U.K. residents) in D.D.C. for fraud, breach of contract, and theft arising from alleged misappropriation of funds from a U.K. bank account.
- Defendants filed a document styled as an answer that the Court treated in part as a motion to dismiss for lack of personal jurisdiction and improper venue.
- Plaintiff alleged defendants have significant U.S. ties generally (family, travel, a "mail drop" business serving U.S. clients, and use of U.S. banks to launder proceeds).
- Plaintiff conceded defendants have no U.S. bank accounts and are domiciled in the U.K.; the alleged theft occurred when funds were taken from a U.K. bank by U.K. residents.
- The District Court evaluated both general and specific personal jurisdiction under D.C. law and due process and resolved factual disputes in plaintiff’s favor where appropriate.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| General personal jurisdiction | Defendants have substantial U.S. ties (family, travel, mail-drop business, servicing U.S. clients) supporting general jurisdiction | Defendants are U.K. domiciliaries without systematic, continuous contacts with D.C. | Denied — contacts alleged were not continuous/systematic or D.C.-specific and did not render defendants "at home" in D.C. |
| Specific personal jurisdiction | Use of U.S. banks and pick-up of cash in U.S. tie the alleged scheme to the U.S./D.C., supporting jurisdiction for the theft claim | The alleged theft occurred in the U.K. by U.K. residents; plaintiff’s claims do not arise from conduct in D.C. | Denied — complaint lacks meaningful connection between the claim and D.C.; relevant conduct occurred abroad. |
| Venue (alternative argument) | N/A (plaintiff filed in D.D.C.) | Defendants argued venue was improper | Not reached — Court dismissed for lack of personal jurisdiction and did not resolve venue. |
Key Cases Cited
- Daimler AG v. Bauman, 134 S. Ct. 746 (general-jurisdiction requires contacts so continuous and systematic the defendant is essentially at home in the forum)
- Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915 (same — restrictive standard for general jurisdiction)
- Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408 (occasional business contacts and travel insufficient for general jurisdiction)
- Walden v. Fiore, 134 S. Ct. 1115 (jurisdictional inquiry focuses on defendant’s contacts with the forum, not contacts with forum residents)
- Int’l Shoe Co. v. Washington, 326 U.S. 310 (framework for due-process analysis of personal jurisdiction)
- Milliken v. Meyer, 311 U.S. 457 (traditional notions of fair play and substantial justice in jurisdictional analysis)
- First Chi. Int’l v. United Exch. Co., 836 F.2d 1375 (D.C. law on specific jurisdiction aligns with constitutional limits)
- FC Inv. Grp. LC v. IFX Mkts., Ltd., 529 F.3d 1087 (statutory and constitutional considerations for jurisdiction under D.C. law)
- Crane v. N.Y. Zoological Soc’y, 894 F.2d 454 (resolve factual disputes in plaintiff’s favor for jurisdictional facts)