Viasystems, Inc. v. EBM-Papst St. Georgen GmbH & Co., KG
2011 U.S. App. LEXIS 14915
| 8th Cir. | 2011Background
- Viasystems filed a federal diversity suit in Missouri against St. Georgen for contract and tort claims related to cooling fans sourced from Germany.
- District court dismissed for lack of personal jurisdiction and denied jurisdictional discovery.
- Fans were manufactured in St. Georgen's Germany plant, shipped to Shanghai, sold to a Chinese subsidiary, and never entered the United States.
- Ericsson paid replacement costs for defective fans; Viasystems partially reimbursed Ericsson and sought further reimbursement from St. Georgen.
- Viasystems challenged the dismissal on jurisdictional grounds and sought discovery to support jurisdiction; the court declined.
- The Eighth Circuit affirmed the dismissal and the denial of jurisdictional discovery.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether St. Georgen is subject to specific jurisdiction in Missouri | Viasystems asserts Missouri long-arm activity and effects-based contacts. | St. Georgen contends contacts are too tenuous for due process. | No prima facie case for specific jurisdiction. |
| Whether St. Georgen is subject to general jurisdiction in Missouri | Viasystems argues streams of commerce and distributor network establish contact. | St. Georgen lacked continuous, systematic contacts; not at home in Missouri. | General jurisdiction not established. |
| Whether the district court abused its discretion by denying jurisdictional discovery | Viasystems sought discovery to bolster jurisdictional facts. | Discovery not warranted where facts core to jurisdiction are undisputed. | No abuse of discretion; discovery denied. |
Key Cases Cited
- World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (U.S. 1980) ( Due process requires minimum contacts.)
- International Shoe Co. v. Washington, 326 U.S. 310 (U.S. 1945) (Minimum contacts to satisfy due process.)
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (U.S. 1985) (Purposeful availment and fair play standards.)
- Goodyear Dunlop Tires Operations, S.A. v. Brown, 131 S. Ct. 2846 (U.S. 2011) (General jurisdiction requires essentially at-home status; stream of commerce insufficient.)
- Barone v. Rich Bros. Interstate Display Fireworks Co., 25 F.3d 610 (8th Cir. 1994) (Stream-of-commerce theory is specific, not general jurisdiction.)
- Epps v. Stewart Info. Servs. Corp., 327 F.3d 642 (8th Cir. 2003) (Agency relationships require control to attribute in-state contacts.)
- Romak USA, Inc. v. Rich, 384 F.3d 979 (8th Cir. 2004) (Long-arm statute and due process inquiries treated separately.)