STATEWIDE TOWING INC v. METRO TOW TRUCKS LTD
1:24-cv-00098
| D. Me. | Nov 25, 2024Background
- Statewide Towing, a Maine company, purchased a custom heavy-duty tow truck (the "Rotator") from Metro Tow Trucks, a Canadian corporation.
- Multiple sales and service interactions occurred, with Metro shipping equipment to Maine, repairing equipment at Maine facilities and dealerships, and repeatedly sending personnel into Maine for service work related to the Rotator.
- Disputes arose over repair failures, Metro's use of the Rotator, and alleged irreparable damage during time held in Canada, after removal from Maine for warranty repairs.
- Statewide filed suit in the District of Maine, asserting negligence and conversion against Metro and other claims against insurance-related defendants.
- Metro moved to dismiss for lack of personal jurisdiction under Rule 12(b)(2), arguing insufficient contacts with Maine.
- The court applied the prima facie standard, accepting Statewide's properly documented facts as true due to factual disputes.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Personal jurisdiction—Relatedness | Metro's conduct in Maine (repairing, transporting Rotator) is central to claims | Metro argues claims arise from conduct/damage in Canada | Court found sufficient nexus; related to Metro's Maine activities |
| Personal jurisdiction—Purposeful availment | Metro deliberately engaged in ongoing business in Maine, targeting Maine market | Metro lacks property, offices, and most operations in Maine | Court found repeated, voluntary Maine contacts, targeting Maine |
| Personal jurisdiction—Reasonableness | Regular Metro trips to Maine minimize any hardship; Maine interest strong | Litigating in Maine is burdensome for Canadian company | Court found no unusual burden; reasonableness met |
| Conversion claim jurisdiction | Metro took control in Maine and removed Rotator under false pretenses | Conversion occurred, if at all, only in Canada | Nexus exists; conversion claim arises from Maine actions |
Key Cases Cited
- Ford Motor Co. v. Mont. Eighth Jud. Dist. Ct., 592 U.S. 351 (2021) (sets standard that defendant’s forum contacts must relate to the claims)
- Bristol-Myers Squibb Co. v. Superior Ct. of Cal., San Francisco Cnty., 582 U.S. 255 (2017) (addresses relatedness in specific jurisdiction)
- Int’l Shoe Co. v. Washington, 326 U.S. 310 (1945) (traditional test for due process in personal jurisdiction)
- PREP Tours, Inc. v. Am. Youth Soccer Org., 913 F.3d 11 (1st Cir. 2019) (prima facie standard and relatedness in the First Circuit)
- Nowak v. Tak How Invs., Ltd., 94 F.3d 708 (1st Cir. 1996) (discusses nexus and purposeful availment for business relationships)
- Phillips Exeter Acad. v. Howard Phillips Fund, 196 F.3d 284 (1st Cir. 1999) (specific jurisdiction and fact-specific inquiry)
- Kuan Chen v. U.S. Sports Acad., 956 F.3d 45 (1st Cir. 2020) (burden of proof and standards for personal jurisdiction motions)