UNITED EMPLOYMENT ASSOCIATES v. LANDMARK CONSTRUCTION COMPANY, INC.
5:23-cv-03668
E.D. Pa.Dec 5, 2024Background
- United Employment Associates (UEA), a Pennsylvania LLC providing employee placement services, brought suit against Landmark Construction Company, Inc. and Port City Concrete, Inc., both South Carolina corporations with common ownership, for unpaid placement fees.
- UEA had an express written contract with Port City, obligating Port City to pay a fee if it hired candidates placed by UEA; no such contract existed with Landmark.
- UEA alleged Landmark hired a candidate (Garcia) whom UEA had introduced, but through a different placement agency, and refused to pay the full fee.
- UEA claimed Port City and Landmark operated as alter egos/sister entities, justifying liability and personal jurisdiction for both under Pennsylvania law.
- After limited discovery, Defendants moved to dismiss for lack of personal jurisdiction and failure to state a claim; the Court considered jurisdiction over both and the sufficiency of claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Personal jurisdiction over Landmark | Landmark is subject to PA jurisdiction as Port City's alter ego or based on contract-related contacts | No sufficient minimum contacts, no contract, no alter ego relationship | No jurisdiction over Landmark |
| Personal jurisdiction over Port City | Port City purposefully directed activities to PA—contract, payments, ongoing dealings | Not disputed as strongly | Jurisdiction over Port City only |
| Breach of contract claim vs. Port City | Port City liable for Landmark's hire under contract terms or based on corporate relationship | Contract covers only Port City hires; no duty for Landmark placements | No plausible breach of contract claim |
| Unjust enrichment/quantum meruit vs. Port City | Placement benefited Port City or both companies; Port City unjustly enriched by Garcia's hire | No benefit to Port City; contract governs, so no quasi-contract remedy | Claims not plausibly pled, but leave to amend granted |
Key Cases Cited
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (purposeful availment is required for specific jurisdiction)
- World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (minimum contacts due process standard for jurisdiction)
- Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408 (general vs. specific jurisdiction distinctions)
- Remick v. Manfredy, 238 F.3d 248 (minimum contacts and contracts in jurisdiction analysis)
- Pearson v. Component Tech. Corp., 247 F.3d 471 (veil piercing and alter ego doctrines)
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading requirements for plausibility)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility standard for Rule 12(b)(6) motions)