Wall v. Corona Capital, LLC
221 F. Supp. 3d 652
W.D. Pa.2016Background
- Plaintiffs Robert and Linda Wall (Pennsylvania residents) invested $152,833.37 under a Master Agreement with Altium Group LLC (Delaware LLC doing business in New Jersey) to purchase structured settlement payments.
- Corona Capital, LLC (Delaware LLC with principal place of business in Florida) purchased Kenneth Stevens’ annuity rights in Florida and sold them through Altium; Corona petitioned a Florida court to approve transfer of payments to the Walls in Pennsylvania.
- A Florida court initially approved the transfer (2012) but later vacated that approval, directing New York Life to pay Stevens’ attorneys instead; the Walls never received payments.
- The Walls sued Altium and Corona in the Eastern District of Pennsylvania alleging breach of transfer warranties, breach of contract, unjust enrichment, and negligence.
- Corona moved to dismiss for lack of personal jurisdiction (or transfer); Altium moved to dismiss or transfer based on a forum selection clause naming Monmouth County, New Jersey.
- The district court dismissed all claims against Corona for lack of personal jurisdiction, retained jurisdiction and venue over Altium, and denied transfer to New Jersey under the Jumara factors because the forum clause was permissive.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Personal jurisdiction over Corona Capital | Corona’s Florida petition directing payments to the Walls in PA and letters to NY Life establish minimum contacts | Corona had no direct contacts with Pennsylvania; Walls contracted with Altium, not Corona | Dismissed for lack of personal jurisdiction — Corona lacked minimum contacts with PA |
| Third-party beneficiary status to establish jurisdiction | Walls claim they were intended beneficiaries of Corona’s agreement with Stevens | Corona denies contract or purposeful availment toward PA | Even if third‑party beneficiaries, mere knowledge or payment routing to PA insufficient for jurisdiction |
| Venue for claims against Altium | Venue proper in E.D. Pa because Altium solicited the Walls via their PA financial advisor and payments/harms occurred in PA | Altium points to Master Agreement forum clause selecting Monmouth County, NJ | Venue proper in E.D. Pa under 28 U.S.C. §1391(b)(2); clause is permissive, so transfer denied |
| Transfer under forum selection clause | Walls: clause is permissive; original forum choice favored | Altium: clause authorizes Monmouth County, NJ as forum; seeks transfer | Clause construed as permissive; Jumara/§1404 balancing favors retaining venue in PA; transfer denied |
Key Cases Cited
- International Shoe Co. v. Washington, 326 U.S. 310 (due process requires minimum contacts)
- World‑Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (defendant must reasonably anticipate being haled into forum)
- Atlantic Marine Construction Co. v. U.S. District Court for Western District of Texas, 571 U.S. 49 (forum‑selection clause analysis and interplay with §1404(a))
- Jumara v. State Farm Insurance Co., 55 F.3d 873 (3d Cir.) (private and public interest factors for venue transfer)
- Allstate Settlement Corp. v. Rapid Settlements, Ltd., 559 F.3d 164 (3d Cir.) (discussion of structured settlement transfer litigation and jurisdiction/venue considerations)