Allstate Property and Casualty Insurance Company v. Samsung Electronics America, Inc.Allstate Property and Casualty Insurance Company v. Samsung Electronics America, Inc.
Plaintiff Allstate Property and Casualty Insurance Company a/s/o James and Linda McQueeney (“Allstate“) brings this subrogated negligence and strict products liability action against several companies that it claims are responsible for damages caused by a leaky dishwasher. Allstate alleges that Midea America Corp. (“Midea“) sold a valve that malfunctioned within the dishwasher. Midea moves to dismiss for lack of personal jurisdiction under
STANDARD OF REVIEW
Once a challenge to personal jurisdiction has been raised under
BACKGROUND1
On November 19, 2022, James and Linda McQueenys’ Samsung dishwasher leaked, causing over $150,000 in damage to their Manchester, New Hampshire home. Allstate, the McQueenys’ insurance company, covered the cost of the damage and now brings this action for strict products liability and negligence against Samsung Electronics America, Inc., Samsung Electronics Home Appliances
According to Allstate‘s investigation of the incident, the McQueeneys’ Samsung dishwasher contained a “water inlet valve component” that failed, causing the dishwasher to malfunction. Doc. no. 49 at 3. Although the valve was manufactured by Bitron, Midea sold the valve to Samsung which, in turn, incorporated it into the faulty dishwasher at issue in this case. Midea supplies water inlet valves to Samsung for incorporation into its dishwashers sold throughout the United States, including in New Hampshire. It also sells its dishwasher valve components to major appliance manufacturers with the “intent and expectation” that the finished appliances will be sold across the country, including in New Hampshire. Id. at 4. Midea derives substantial revenue from the sale and supply of components incorporated into household appliances that are sold nationwide by retailers like Best Buy and Home Depot. Moreover, Allstate alleges that “Midea maintains United States-based operations intended to support nationwide sales, compliance, and distribution operations designed to serve their national customer base, including consumers in the State of New Hampshire.” Id.
In Count V, Allstate claims that Midea is strictly liable for placing the valve at issue into the stream of commerce in an unreasonably dangerous condition. In
Allstate objects to Midea‘s motion to dismiss and, in the alternative, seeks jurisdictional discovery.3 Along with its objection, Allstate submits the following factual proffer: Midea maintains a website with a “Service Locator” feature that enables users to search for “a Midea Authorized Service Provider near you” by entering a zip code. Doc. no. 41-2 at 2. The Service Locator feature reveals that “Anything Appliance” (in Hooksett, New Hampshire) is a Midea-authorized service provider. Id.
On April 30, 2026, this court issued an order scheduling oral argument on the motion to dismiss. The order alerted the parties that the court wanted to hear more
DISCUSSION
The plaintiff bears the burden of demonstrating that personal jurisdiction exists. See Knox v. MetalForming, Inc., 914 F.3d 685, 690 (1st Cir. 2019). When a federal court exercising diversity jurisdiction entertains a personal-jurisdiction challenge, the court acts “as ‘the functional equivalent of a state court sitting in the forum state.‘” Rosenthal v. Bloomingdales.com, LLC, 101 F.4th 90, 94-95 (1st Cir. 2024) (quoting Astro-Med, Inc. v. Nihon Kohden Am., Inc., 591 F.3d 1, 8 (1st Cir. 2009)). Thus, to establish personal jurisdiction over Midea, Allstate “must satisfy the requirements of both New Hampshire‘s long-arm statute—which defines the scope of personal jurisdiction over a defendant in that state‘s courts—and the Due Process Clause of the Fourteenth Amendment to the U.S. Constitution.” Stokinger v. Armslist, LLC, 166 F.4th 229, 233 (1st Cir. 2026). Because New Hampshire‘s long-arm statute “reaches to the full extent that the Constitution allows,” the court‘s only inquiry is whether exercising personal jurisdiction would comport with due process. Phillips Exeter Acad. v. Howard Phillips Fund, 196 F.3d 284, 287 (1st Cir. 1999).
To show that exercising personal jurisdiction over Midea would comply with due process, Allstate must establish that Midea had “certain minimum contacts
Because Allstate fails to satisfy the first prong (relatedness), the court‘s analysis extends only to this prong.
I. Allstate Fails to Establish its Claims Are Related to Midea‘s Forum Contacts
To establish relatedness, Allstate must demonstrate that its claims “arise out of or relate to” Midea‘s contacts with New Hampshire. Ford Motor Co. v. Montana Eighth Jud. Dist. Ct., 592 U.S. 351, 359 (2021) (quoting Bristol-Myers Squibb Co. v. Super. Ct., 582 U.S. 255, 262 (2017)). The relatedness prong requires “a demonstrable nexus between the complaint‘s claims and the activities in the forum that properly may be attributed to the defendant[ ], such that the litigation itself is founded directly on those activities.” Laundry v. Peddinghaus Corp., Civ. No. 22-cv-185-AJ, 2024 WL 3797600, at *4 (D.N.H. July 24, 2024) (alteration in original) (quoting PREP Tours, Inc. v. Am. Youth Soccer Org., 913 F.3d 11, 18 (1st Cir. 2019)). As the Supreme Court explained in Ford, the “phrase ‘relate to’ suggests ‘that some relationships will support jurisdiction without a causal showing.‘” O‘Neil v. Somatics, LLC, Civ. No. 20-cv-175-PB, 2021 WL 4395115, at *3 (D.N.H. Sept. 24, 2021) (quoting Ford Motor Co., 592 U.S. at 362). However, that “does not mean anything goes . . . the phrase ‘relate to’ incorporates real limits, as it must to adequately protect defendants foreign to a forum.” Ford Motor Co., 592 U.S. at 362.
Here, Allstate‘s product liability and negligence claims against Midea stem from allegations that Midea distributed a defective valve which Samsung incorporated into the McQueeney‘s dishwasher. Allstate points to Midea‘s affiliation with Anything Appliance (in Hooksett, New Hampshire), which Midea holds out as an “Authorized Service Provider” on its website. Allstate does not, however, offer any argument as to how its claims against Midea (pertaining to its distribution of an allegedly defective valve manufactured by a different company) arise out of or relate to Midea‘s affiliation with Anything Appliance.
To begin, there is no causal relationship between this contact and Allstate‘s claims. Whether Midea has a relationship with a third-party service provider in New Hampshire has “no bearing” on whether the valve that Midea distributed to Samsung was defectively designed or manufactured. O‘Neil, 2021 WL 4395115, at *4. This is particularly true where the complaint does not allege that the dishwasher or valve at issue was sold by or repaired by Anything Appliance. Nor does the complaint state a claim for negligent repair. For these reasons, Allstate has not shown that its claims “arise out of” Midea‘s New Hampshire contacts.
Not only do the claims fail to “arise out of” Midea‘s New Hampshire contacts, Allstate‘s claims do not “relate to” those contacts. There is not a “strong
For these reasons, Allstate‘s claims against Midea do not arise out of or relate to Midea‘s forum contacts.
The First Circuit recently set out the standard for obtaining jurisdictional discovery:
Generally, a diligent plaintiff who sues an out-of-state corporation and who makes out a colorable case for the existence of in personam jurisdiction may well be entitled to a modicum of jurisdictional discovery if the corporation interposes a jurisdictional defense. The entitlement to such discovery is not absolute. To merit jurisdictional discovery, plaintiffs must demonstrate diligence by presenting facts to the court which show why jurisdiction would be found if discovery were permitted, and explaining what relevant information they hope to glean through such discovery. Even where plaintiffs meet those requirements, the district court still has broad discretion to decide whether discovery is required.
Putnam v. EPR Props., 174 F.4th 214, 226 (1st Cir. 2026) (brackets, ellipses, and quotations omitted).
In addition to requiring a colorable case for jurisdiction and diligence, the “First Circuit has recognized that parties do not properly present a request for jurisdictional discovery by ‘merely mentioning the option of jurisdictional discovery in an opposition to a motion to dismiss.‘” Stokinger v. Armslist, LLC, Civ. No. 23-cv-428-PB-TSM, 2024 WL 3411108, at *8 (D.N.H. July 15, 2024) (brackets omitted) (quoting Motus, LLC v. CarData Consultants, Inc., 23 F.4th 115, 127-28 (1st Cir. 2022)) rev‘d in part on other grounds, 166 F.4th 229 (1st Cir. 2026); see also id. (explaining that LR 7.1(a)(1) provides that parties may not “combine multiple motions seeking separate and distinct relief into a single filing“). Allstate has come up short across the board.
Allstate‘s lack of diligence is reason alone to deny the request. But the request also fails on the merits. Allstate has not shown “why jurisdiction would be found if discovery were permitted” or explained “what relevant information [it] hope[s] to glean through such discovery.” Putnam, 174 F.4th at 226 (quotations omitted). Unable to conclude that Allstate‘s one-sentence request would cure the deficiencies evident in the relatedness inquiry discussed above, the court sua sponte gave Allstate another chance to make its best case for jurisdictional discovery in an oral argument before the court. See Endorsed Order of April 30, 2026 (directing Allstate to address at oral argument “how [jurisdictional] discovery might allow Allstate to establish that its claims arise out of or relate to Midea‘s forum contacts“). At oral argument, however, Allstate failed to explain what “relevant information”
Because Allstate has failed to make out a colorable case for the existence of personal jurisdiction and to act diligently in pursuing jurisdictional discovery, its request for jurisdictional discovery is denied.
CONCLUSION
For all these reasons, Midea‘s motion to dismiss for lack of personal jurisdiction (doc. no. 40) is granted, and Allstate‘s request for jurisdictional discovery is denied. All claims against Midea are dismissed without prejudice.
SO ORDERED.
_________________________
Landya McCafferty
United States District Judge
July 21, 2026
cc: Counsel of Record