149 F. Supp. 3d 1121
S.D. Iowa2015Background
- Plaintiff State Central Bank (Iowa) sued defendant John F. Berzanskis (Illinois resident) to collect on a series of promissory notes totaling over $500,000 (five notes executed 2003–2010); at filing, debt ~$488,646.48.
- Last payment was October 28, 2014; State Central sent cure and acceleration notices in January–February 2015.
- State Central filed in Iowa state court March 16, 2015; Berzanskis was served April 2, 2015 and removed to federal court based on diversity.
- Berzanskis moved to dismiss under Rule 12(b)(2) for lack of personal jurisdiction, arguing he has no meaningful contacts with Iowa (signed notes in Illinois, payments from Illinois accounts, no forum clause).
- State Central submitted affidavits and loan records showing repeated communications with its Iowa loan officer, multiple loans obtained to fund an Iowa business (Custom Hardware Manufacturing, Inc.), routing/disbursement of funds to Iowa entities, and Iowa choice-of-law provisions in the notes.
- The court denied the motion, finding State Central made a prima facie showing of specific jurisdiction based on purposeful availment through repeated, targeted loan transactions tied to an Iowa business.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Iowa has specific personal jurisdiction over Berzanskis | Berzanskis repeatedly solicited loans from an Iowa bank to fund an Iowa business, engaged in multi-year communications and disbursements to Iowa entities, and thus purposefully availed himself of Iowa's laws | Berzanskis never did business in Iowa, signed notes in Illinois, paid from Illinois accounts, made no calls to Iowa, and was only introduced to the bank by a third party; choice-of-law alone is insufficient | Denied motion: specific jurisdiction exists — contacts (nature, quantity, and relation to claim) show purposeful availment and foreseeability of litigation in Iowa |
Key Cases Cited
- Int’l Shoe Co. v. Washington, 326 U.S. 310 (established minimum-contacts due process standard)
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (purposeful availment, contractual relations and choice-of-law considered in jurisdictional analysis)
- K-V Pharm. Co. v. J. Uriach & CIA, S.A., 648 F.3d 588 (prima facie burden and purposeful-availment discussion in 8th Circuit)
- Creative Calling Sols., Inc. v. LF Beauty Ltd., 799 F.3d 975 (Iowa long-arm inquiry limited to due process reach)
- Downing v. Goldman Phipps, PLLC, 764 F.3d 906 (8th Circuit five-factor test for specific jurisdiction)