Summary
The Ninth Circuit affirmed dismissal of a diversity action for lack of personal jurisdiction over a Michigan defendant. The court held that the defendant did not purposefully avail himself of conducting activities in California through the alleged oral agreement or his limited California trips, and did not expressly aim his alleged tortious interference at California. The court therefore concluded that specific personal jurisdiction was lacking for both the declaratory judgment and intentional interference claims.
Topics
Practice areas
Questions Presented
- Whether California courts could exercise specific personal jurisdiction over Weston on Picot's declaratory judgment claim concerning the alleged oral agreement.
- Whether California courts could exercise specific personal jurisdiction over Weston on Picot's intentional-interference-with-contract claim.
Holdings
- Weston's alleged oral agreement and his two trips to California did not establish that he purposefully availed himself of the privilege of conducting activities in California, and therefore did not create sufficient minimum contacts for specific personal jurisdiction.
- Weston did not expressly aim his alleged intentional interference at California because his conduct occurred in Michigan, involved communications with persons and entities outside California, and caused an injury not meaningfully tethered to California.
Key quotations
“Accordingly, we hold that the oral agreement and Weston’s two trips to California did not create sufficient minimum contacts to subject him to personal jurisdiction there.” (780 F.3d at 1216)
“Weston neither purposefully availed himself of the privilege of conducting activities in California nor expressly aimed his conduct at California.” (780 F.3d at 1219)
Factual background
Picot, a California resident, and Weston, a Michigan resident, worked with Manos to develop and market an electrolyte technology. Weston claimed that an oral agreement entitled him to compensation and a one-third share of sale proceeds; Picot denied that any agreement existed. Weston performed most of his alleged contractual work in Michigan, made two short trips to California for demonstrations, and later allegedly interfered with Picot and Manos's sale of the technology to HMR by making statements from Michigan to individuals and entities outside California.
Procedural history
Picot and Paul David Manos sued Weston in California state court seeking a declaration that no oral agreement existed and damages for intentional interference with a sales contract. Weston removed the action to the United States District Court for the Northern District of California, moved to dismiss for lack of personal jurisdiction and improper venue, and alternatively sought transfer to the Eastern District of Michigan. The district court dismissed for lack of personal jurisdiction and denied the transfer motion as moot. Picot, but not Manos, timely appealed.