577 S.W.3d 490
Mo.2019Background
- Plaintiff Lincoln Rene Aguiriano Martinez, a Kansas resident, was electrocuted while working at an apartment complex in Overland Park, Kansas, and sued for damages in Jackson County, Missouri.
- Relators Cedar Crest Apartments, LLC and Peterson Properties, Inc. are Kansas business entities with principal places of business and employees in Kansas; Peterson Enterprises is a Missouri corporation and managing member/owner of those entities.
- Martinez alleged Relators owned/controlled the Kansas property and relied on Relators’ Missouri contacts (business registration, soliciting business, filing suits, owning unrelated property) and relationship with Missouri Peterson Enterprises to support Missouri jurisdiction.
- Relators moved to dismiss for lack of personal jurisdiction; the trial court denied the motion, prompting Relators to seek a writ of prohibition — ultimately granted by the Missouri Supreme Court.
- The Court evaluated both general (all-purpose) and specific (claim-linked) jurisdiction under Missouri’s long-arm statute and federal due-process constraints, and rejected Martinez’s theories imputing Peterson Enterprises’ Missouri contacts to the Relators.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Missouri courts have general jurisdiction over Relators | Relators’ systematic, continuous Missouri contacts (registration, soliciting, litigation, property) and parent’s Missouri domicile make them "at home" in Missouri | Relators are Kansas entities with Kansas POB; their Missouri contacts are insufficient to render them "at home" here | No general jurisdiction; contacts do not meet Daimler’s "at home" standard |
| Whether Missouri courts have specific jurisdiction over Relators | Relators’ Missouri activities demonstrate contacts and purposeful availment sufficient to link Martinez’s claim | Martinez’s claims arose from events in Kansas and do not arise out of Relators’ Missouri contacts | No specific jurisdiction; plaintiff failed to show claim arises from forum contacts |
| Whether Peterson Enterprises’ Missouri contacts may be imputed to Relators (agency/principal–agent theory) | Peterson Enterprises manages/owns Relators and makes decisions for them, so its Missouri contacts should be imputed to Relators | One corporation’s domicile or contacts cannot be imputed to separate foreign entities absent agency or alter-ego showing | Rejected; plaintiff failed to allege or prove agency/alter-ego sufficient to impute contacts |
| Whether the corporate veil should be pierced to establish jurisdiction | Plaintiff urged that control/ownership by Missouri Peterson Enterprises supports jurisdiction (veil-piercing) | Corporate separateness presumptively applies; plaintiff must plead and prove domination, misuse for wrong, and causation | Rejected; plaintiff failed to plead facts showing complete domination and improper purpose required to pierce veil |
Key Cases Cited
- State ex rel. Bayer Corp. v. Moriarty, 536 S.W.3d 227 (Mo. banc 2017) (overview of personal-jurisdiction principles in Missouri)
- State ex rel. Norfolk S. Ry. Co. v. Dolan, 512 S.W.3d 41 (Mo. banc 2017) ("at home" analysis and limits on general jurisdiction over non‑domiciliaries)
- Daimler AG v. Bauman, 571 U.S. 117 (U.S. 2014) (general jurisdiction limited to place of incorporation or principal place of business except in exceptional cases)
- Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915 (U.S. 2011) (general jurisdiction principles for foreign corporations)
- Perkins v. Benguet Consol. Mining Co., 342 U.S. 437 (U.S. 1952) (exceptional-case precedent for general jurisdiction)
- Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408 (U.S. 1984) (distinction between doing business and being "at home")
- Bristol-Myers Squibb Co. v. Superior Court of California, 137 S. Ct. 1773 (U.S. 2017) (specific-jurisdiction requirement that claim arise out of defendant’s forum contacts)