Law School Case Brief
Metro. Life Ins. Co. v. Robertson-Ceco Corp. - 84 F.3d 560 (2d Cir. 1996)
The due process test for personal jurisdiction has two related components: the minimum contacts inquiry and the reasonableness inquiry. The court must first determine whether the defendant has sufficient contacts with the forum state to justify the court’s exercise of personal jurisdiction. For purposes of this initial inquiry, a distinction is made between specific jurisdiction and general jurisdiction.
Plaintiff Met Life, a New York corporation with its principal place of business in New York, filed a complaint against Defendants Robertson-Ceco (Robertson) and United Dominion Industries, Ltd. in the United States District Court for the District of Vermont alleging, inter alia, state breach of contract and negligence claims. Robertson was a Delaware corporation with its principal place of business in Pennsylvania. Robertson moved to dismiss the suit for, among others, lack of personal jurisdiction, claiming, inter alia, that there was no allegation that Met Life's claims arose out of any business conducted by Robertson in Vermont, or that Robertson had a substantial and continuous presence in Vermont justifying the exercise of personal jurisdiction. Met Life responded by filing a notice of intent to depose a corporate representative of Robertson on 49 topics relating to Robertson's business activities in Vermont, which directed Robertson to produce all relevant documents without any date restrictions or limitations. The district court found Met Life's discovery request overbroad and issued a protective order, which limited plaintiff's discovery of defendant company's business contacts with the forum state and granted defendant's motion to dismiss for lack of personal jurisdiction under Fed. R. Civ. P. 12(b)(2). Met Life filed a notice of appeal.
Did the federal district court correctly dismiss Met Life’s complaint for lack of personal jurisdiction?
The Court of Appeals for the Second Circuit held that the due process test for personal jurisdiction had two related components: the minimum contacts inquiry and a five-factor reasonableness inquiry. According to the Court, although Robertson had minimum contacts with Vermont, in the absence of any cognizable interest on the part of Met Life or the state of Vermont in adjudicating Met Life’s claims in Vermont, the exercise of jurisdiction would violate traditional notions of fair play and substantial justice based on the reasonableness inquiry applied to general jurisdiction cases.
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