Roman Catholic Diocese of Albany, New York, Inc. v. Roman Catholic Diocese of Albany, New York, Inc.
745 F.3d 30
| 2d Cir. | 2014Background
- Shovah sued the Diocese of Albany and a former priest in D. Vermont alleging priest transported and sexually abused him in the late 1980s; the Diocese sought dismissal for lack of personal jurisdiction.
- The district court held the Diocese was 'at home' in Vermont, imputing some priests’ Vermont-worship services and other contacts to establish general jurisdiction.
- The Diocese is a New York special act corporation with its main office in Albany; it has no Vermont property, offices, or bank accounts, and most activities occur in New York.
- Six border parishes served Vermont residents and employed Vermont residents; Vermont vendors and advertisers were used sparingly, and Vermont subscribers/patrons were a small fraction of the Diocese’s overall reach.
- The district court ordered broad discovery into past investigations of sexual abuse involving Diocese employees, threatening disclosure of sensitive materials.
- The panel granted expedited consideration for mandamus, stayed district court proceedings, and now vacates the district court order directing dismissal for lack of jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is mandamus available to review a district court’s jurisdiction ruling? | Diocese: mandamus necessary due to irreparable harm from discovery and time-bar risks. | Shovah: mandamus is extraordinary and typically not available for interlocutory rulings. | Yes, extraordinary mandamus warranted under exceptional circumstances. |
| Does Vermont constitute the Diocese’s general jurisdiction 'home'? | Shovah: Vermont contacts render Diocese at home. | Diocese: contacts are insufficient; Vermont is not home. | Vermont is not the Diocese’s general jurisdiction home; no general jurisdiction. |
| Was the district court's general-jurisdiction determination a clear abuse of discretion? | Shovah: district court erred in Goodyear/Daimler framework and imputations. | Diocese: district court carefully considered contacts and imputations. | Yes, district court abused its discretion; mandamus warranted. |
Key Cases Cited
- Daimler AG v. Bauman, 134 S. Ct. 746 (2014) (limits general jurisdiction; at-home concept not easily extended)
- Goodyear Tire & Rubber Co. v. Brown, 131 S. Ct. 2846 (2011) (limits all-purpose jurisdiction; ‘continuous and systematic’ contacts required)
- Perkins v. Benguet Consol. Mining Co., 342 U.S. 437 (1952) (classic general-jurisdiction case; forum as temporary home)
- Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408 (1984) (mere purchases not enough for general jurisdiction)
- International Shoe Co. v. Washington, 326 U.S. 310 (1945) (minimum contacts standard for jurisdiction)
- Sims v. Blot, 534 F.3d 117 (2d Cir. 2008) (abuse-of-discretion standard; jurisdiction ruling reviewable for error)
- Coopers & Lybrand v. Livesay, 437 U.S. 463 (1978) (final-judgment rule and interlocutory review limitations)