Law School Case Brief
Katzenbach v. Grant - No. 1:04-cv-6501 OWW LJO, 2005 U.S. Dist. LEXIS 46756 (E.D. Cal. June 7, 2005)
Determining whether a court may exercise personal jurisdiction over a defendant is ordinarily a two-step process: (1) whether the forum state's long-arm statute reaches the defendant; and (2) whether the exercise of jurisdiction comports with the federal constitutional principle of due process. For a defendant to be subject to personal jurisdiction in the forum state, due process requires that the defendant must have certain minimum contacts with the forum state such that the maintenance of the suit does not offend "traditional notions of fair play and substantial justice. Due process may be satisfied by establishing that one of two forms of personal jurisdiction exists: general jurisdiction or specific jurisdiction. General jurisdiction exists when a defendant "is domiciled in the forum state" or has "substantial" or "continuous and systematic" contacts with the forum state, even if the cause of action does not arise out of or relate to those contacts. If, however, a forum state cannot assert general jurisdiction over the defendant, it may still assert specific jurisdiction depending on the quality and nature of the defendant's contacts with the forum state in relation to the cause of action. To determine whether the district court can exercise specific jurisdiction over the defendants, courts apply a three-part test.
Plaintiffs Ryan Katzenbach's and Ric Osuna filed a federal complaint against the Defendant Greg S. Grant, alleging that the Defendant interfered with Plaintiffs’ negotiations with Sony Pictures and the USA Networks to produce a movie by sending a letter to Sony Pictures that claimed Plaintiff Osuna’s book was a fraud. Plaintiffs further alleged that Defendant published the letter and other defamatory statements about Plaintiffs on his website. Defendant filed a motion to dismiss Plaintiff’s complaint for lack of personal jurisdiction pursuant to Fed. R. Civ. P. 12(b)(2) and for failure to state a claim pursuant to Fed. R. Civ. P. 12(b)(6). Plaintiffs opposed the motion, arguing that the Defendant, a citizen of South Carolina, had consented to a personal jurisdiction in Santa Clara County, California when he signed a waiver of personal jurisdiction in a separate contract of sale with E-Bay. Moreover, Plaintiffs noted that Defendant’s website was a commercial website interacting with a California Corporation, thereby giving the California court authority to exercise jurisdiction over the Defendant.
- May the U.S. District Court of California exercise personal jurisdiction over Defendant Grant?
- Did the Plaintiffs’ Amended Complaint fail to state a claim, thus requiring dismissal of their complaint?
Upon finding that Plaintiffs failed to establish a prima facie case that either general or specific jurisdiction exist over Defendant, the U.S. District Court for the Eastern District of California granted Defendant's motion to dismiss for lack of personal jurisdiction, pursuant to Fed. R. Civ. P. 12(b)(6). The Court noted that in order for a defendant to be subject to personal jurisdiction in the forum state, due process required that the defendant must have certain minimum contracts with the forum state such that the maintenance of the suit would not offend “traditional notions of fair play and substantial justice.” In the case at bar, the court held that Defendant’s contract with a California corporation, without something more, was insufficient to establish a general personal jurisdiction in a California court. Moreover, the Court held that the subject matter of the present complaint did not arise out of the E-Bay contract; thereby, it was not sufficient to grant the California court personal jurisdiction over the Defendant.
Next, the Court held that because Plaintiffs had alleged intentional torts, application of the three-prong effects test is therefore appropriate here. However, Plaintiffs' argument for specific personal jurisdiction under the three-part effects test failed. Plaintiffs have not established the second element, "express aiming," of the effects test based on Defendant's posting of information to his website. Plaintiffs have failed to establish the purposeful availment element based on Grant's posting of information on his website.
Explaining its reasons for each claim, the Court concluded that Plaintiffs did not satisfy the elements of their respective claims; accordingly, Defendant’s motion to dismiss based on failure to state a claim was granted.
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