Watson v. Golden North Van Lines, Inc.
2:24-cv-02227
W.D. Tenn.Dec 3, 2024Background
- Plaintiff Robert Watson sued Golden North Van Lines, Inc. and Serena Kraft in Tennessee state court for defamation, tortious interference, and respondeat superior liability; the case was removed to federal court based on diversity jurisdiction.
- Watson, formerly an officer and minority shareholder of Relocation Management Worldwide, Inc. (RMW), alleges Kraft (representing Golden North) sent defamatory texts to another RMW shareholder that accused Watson of stealing from RMW, leading to his termination.
- The allegedly defamatory communications occurred during Golden North’s due diligence process as it considered investing in or acquiring RMW, a Tennessee business.
- Kraft traveled to Tennessee, met with RMW staff, and furthered Golden North’s investigation into RMW’s finances.
- Defendants moved to dismiss for lack of personal jurisdiction and failure to state a claim, arguing (1) insufficient contacts with Tennessee, and (2) that the statements were protected by the common interest privilege.
- The district court denied the motion, holding that specific jurisdiction was proper and common interest privilege did not warrant dismissal at this stage.
Issues
| Issue | Watson's Argument | Defendants' Argument | Held |
|---|---|---|---|
| Specific personal jurisdiction over defendants in Tennessee | Defendants purposely availed themselves via business activities and alleged wrongdoing occurred in TN | Contacts were insufficient, limited to due diligence and NDA, not targeted at TN benefit | Jurisdiction proper; Defendants purposefully availed themselves |
| Claim arises out of contacts with state | Claims stem from Kraft’s texts and meetings in TN, leading to termination | Actions not meaningfully connected to TN concerning the controversy | Arises from contacts; strong connection |
| Reasonableness of exercising jurisdiction | Reasonable; Defendants took direct actions in TN and dispute relates to TN company | Unreasonable and unfair due to minimal contacts and Plaintiff's current KY residency | Reasonable to exercise jurisdiction |
| Application of common interest privilege | Privilege does not extend to preliminary merger talks or prospective investments under TN law | Privilege applies; both parties shared interest in RMW’s financial wellbeing | Privilege not applicable; court declines to expand TN law for merger talks |
| Appropriateness of dismissal under 12(b)(6) | Dismissal on privilege grounds is premature as factual development is needed | Dismissal appropriate if privilege bars claim | Inappropriate to dismiss at this stage; claim survives |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (plausibility standard for pleadings in federal court)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading standard for Rule 12(b)(6) motions)
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (purposeful availment for personal jurisdiction)
- World–Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (minimum contacts test for due process)
- Int’l Shoe Co. v. State of Wash., Off. of Unemployment Comp. & Placement, 326 U.S. 310 (due process requirements for jurisdiction)
- S. Mach. Co. v. Mohasco Indus., Inc., 401 F.2d 374 (three-part test for specific personal jurisdiction in the Sixth Circuit)
- Davis v. Tennessean, 83 S.W.3d 125 (Tenn. Ct. App.) (standard for defamation under Tennessee law)
- Sullivan v. Baptist Mem’l Hosp., 995 S.W.2d 569 (Tenn.) (definition of publication in defamation)