Quality Professional Industries Inc. v. Sun Power Corporation, 1:15-cv-01390

Background

Plaintiffs MaryAnn Quilala and Michael Watkins (pro se) allege defendants (SunPower, MatriScope, Mortenson, Merced County and individual officers) used improper wire and concealed safety violations during a Merced County, California construction project; Watkins, an inspector, claims harassment, injury, threats, and termination after reporting the issues.
The amended complaint asserts federal-question and diversity jurisdiction and pleads claims including breach of contract, physical injury, mental anguish, and public-safety torts; plaintiffs are residents of Hawaii (but later appear to have moved back to California).
Defendants are primarily California or Minnesota entities/individuals; the alleged events and contract (a subconsulting agreement) arose and were performed in California.
Defendants moved to dismiss for lack of personal jurisdiction (SunPower Defendants and Mortenson Defendants); Mortenson also argued failure to state a claim but the court focused on jurisdictional issues.
The court found plaintiffs failed to show either general or specific jurisdiction over any defendant in Hawaii because defendants lacked the continuous, systematic contacts required for general jurisdiction and the claims did not arise from forum-related activities required for specific jurisdiction.
In lieu of dismissal, the court transferred the action to the Eastern District of California under 28 U.S.C. § 1631 as that district could have exercised jurisdiction and transfer served the interests of justice.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court has general jurisdiction over defendants	Plaintiffs contend defendants (esp. SunPower) do business in Hawaii (e.g., solar projects) sufficient for jurisdiction	Defendants assert they are not "essentially at home" in Hawaii; principal places of business/offices are outside Hawaii	Court held no general jurisdiction: contacts were not "constant and pervasive" or "essentially at home"
Whether the court has specific jurisdiction over defendants	Plaintiffs argue Hawaii is proper because they are Hawaii residents and defendants have some Hawaii contacts	Defendants argue the claims arise from California conduct and lack purposeful availment/intentional acts aimed at Hawaii	Court held no specific jurisdiction: plaintiffs failed prongs of purposeful availment/direction and forum-relatedness
Whether exercising jurisdiction would be reasonable	Plaintiffs imply convenience and venue tie to Hawaii	Defendants emphasize burden, location of evidence/witnesses in California and sovereignty concerns	Court held exercise of jurisdiction would be unreasonable under the Menken factors
Whether the case should be dismissed or transferred if jurisdiction lacking	Plaintiffs requested transfer to a California federal district near Merced County	Defendants did not oppose transfer as alternative to dismissal	Court transferred case to the Eastern District of California in the interest of justice

Key Cases Cited

International Shoe Co. v. Washington, 326 U.S. 310 (established due process minimum-contacts standard for personal jurisdiction)
Goodyear Dunlop Tires Operations, S.A. v. Brown, 131 S. Ct. 2846 (general jurisdiction permits hearing all claims only where corporation is essentially at home)
Daimler AG v. Bauman, 134 S. Ct. 746 (general jurisdiction doctrine: place of incorporation or principal place of business norm; exceptional cases only otherwise)
Menken v. Emm, 503 F.3d 1050 (three-part specific jurisdiction test and plaintiff’s burden to make prima facie showing)
Schwarzenegger v. Fred Martin Motor Co., 374 F.3d 797 (plaintiff bears burden to show personal jurisdiction; standards for specific jurisdiction analyses)
Dole Food Co. v. Watts, 303 F.3d 1104 (effects test for purposeful direction in tort cases)
Erickson v. Pardus, 551 U.S. 89 (pro se complaints are held to less stringent standards)