2022 Ohio 1860
Ohio Ct. App.2022Background
- Ricker (Ohio resident) entered into a remote contract to buy a Mercedes‑Benz E450 from Mercedes‑Benz of Georgetown (MBG), a Texas dealer; MBG is a subsidiary of Group 1 and payment was routed to an entity named Sterling McCall.
- Ricker’s daughter gave MBG his contact info; MBG salespeople called Ricker in Ohio, negotiated price by phone, mailed a contract to Ohio, Ricker signed and returned it, wired $75,000 from an Ohio bank, and paid the balance by phone from Ohio.
- MBG later refused to deliver the vehicle, refunded most of the payment, and Ricker sued in Franklin County for breach of contract, OCSPA violations, and fraud/misrepresentation.
- Defendants moved to dismiss for lack of personal jurisdiction; the trial court (without an evidentiary hearing) found MBG transacted business but that exercising jurisdiction would violate due process, and dismissed all defendants.
- The Tenth District reversed: viewing the record in Ricker’s favor, it held a prima facie showing of specific personal jurisdiction over MBG under Ohio’s long‑arm statute and the Due Process Clause, and remanded for further proceedings and reassessment of jurisdiction over Group 1 and Sterling McCall.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Ohio courts have personal jurisdiction over MBG | MBG purposefully availed itself of Ohio by initiating contact with Ricker in Ohio, negotiating and mailing the contract to Ohio, and receiving payments wired/charged from Ohio; claims arise from those in‑state activities | MBG lacked continuous/systemic Ohio contacts; this was a single out‑of‑state transaction initiated by the daughter and conducted by phone/mail, so due process precludes jurisdiction | Reversed trial court: prima facie specific jurisdiction exists. MBG purposefully availed itself; claims arise from those contacts; exercising jurisdiction is reasonable. Case remanded for further proceedings and to reassess jurisdiction over affiliates. |
Key Cases Cited
- Internatl. Shoe Co. v. Washington, 326 U.S. 310 (establishes minimum‑contacts due process framework)
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (purposeful availment and foreseeability in specific jurisdiction analysis)
- Ford Motor Co. v. Montana Eighth Judicial Dist. Court, 141 S. Ct. 1017 (distinguishing general and specific jurisdiction and scope of relatedness)
- S. Machine Co. v. Mohasco Indus., 401 F.2d 374 (6th Cir.) (three‑part test applied by Ohio courts for specific jurisdiction)
- Kentucky Oaks Mall Co. v. Mitchell's Formal Wear, Inc., 53 Ohio St.3d 73 (Ohio long‑arm interpretation: telephone negotiation + mailed contract can be transacting business)
- Goodyear Dunlop Tires Ops., S.A. v. Brown, 564 U.S. 915 (general jurisdiction—‘at home’ standard for corporations)
- World‑Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (foreseeability and limits on jurisdiction based on contacts)
- McGee v. Internatl. Life Ins. Co., 335 U.S. 220 (single act can, in context, support jurisdiction)