Structured Financial, LLC v. Shonuff Digital Media, LLC
5:24-cv-00687
E.D.N.C.Apr 30, 2025Background
- Structured Financial, LLC, a Michigan LLC with its principal place of business in North Carolina, loaned $250,000 to Shonuff Digital Media, LLC, a Georgia company.
- The loan was memorialized by a promissory note, which included a personal guaranty signed by William and Tamara Chavis, Georgia residents.
- Defendants allegedly failed to repay the loan by the agreed deadline in October 2023, giving rise to breach of contract claims for both the note and guaranty.
- Structured Financial filed suit in the Eastern District of North Carolina seeking damages.
- William and Tamara Chavis, representing themselves, moved to dismiss the case, arguing lack of personal jurisdiction and improper venue.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Improper Venue (12(b)(3)) | Venue proper—substantial part of events in NC | Venue improper—breach occurred in Georgia | Denied; venue proper in NC |
| Lack of Personal Jurisdiction (12(b)(2)) | Sufficient contacts—loan applied for, issued, and accepted in NC | No personal jurisdiction as GA residents | Denied; minimum contacts established |
| Substantiality of NC-based events | Funding, application, and acceptance all in NC | Focus only on place where default occurred | Events in NC are substantial |
| Burden of Litigating in NC | NC is plaintiff’s principal business location | Litigation in NC is burdensome and unfair | Not unduly burdensome for defendants |
Key Cases Cited
- Mitrano v. Hawes, 377 F.3d 402 (4th Cir. 2004) (venue analysis must look at all events giving rise to claim, not only those in dispute)
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985) (minimum contacts for personal jurisdiction require purposeful availment)
- Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408 (1984) (due process requires minimum contacts for personal jurisdiction)
- Ford Motor Co. v. Montana Eighth Judicial District Court, 592 U.S. 351 (2021) (specific jurisdiction requires claims to arise out of or relate to defendant's forum contacts)
- Bristol-Myers Squibb Co. v. Superior Court, 582 U.S. 255 (2017) (case must relate to defendant’s contacts with forum for specific jurisdiction)