Soma Medical International v. Standard Chartered Bank

Summary

The Tenth Circuit affirmed dismissal of Soma Medical International’s diversity action against Standard Chartered Bank for lack of personal jurisdiction. The court held that the bank’s contacts with Utah, including correspondence concerning a Hong Kong account and a passive website, did not establish general or specific jurisdiction. The court also affirmed denial of Soma’s motion to compel jurisdictional discovery.

Holdings

1. Standard Chartered Bank's Utah-related filings, prior Utah lawsuits, and passive informational website did not constitute the substantial and continuous local activity necessary for general personal jurisdiction.
2. Standard Chartered Bank's account-related communications, records, and transfers were insufficient to establish minimum contacts or purposeful availment supporting specific personal jurisdiction in Utah.
3. The magistrate judge did not abuse his discretion by denying Soma's motion to compel jurisdictional discovery.

Questions Presented

1. Whether the Utah federal court could exercise general personal jurisdiction over Standard Chartered Bank based on its Utah-related filings, prior Utah litigation, website, and other activities.
2. Whether the Utah federal court could exercise specific personal jurisdiction over Standard Chartered Bank based on the bank's communications and account-related contacts with Soma in Utah.
3. Whether the magistrate judge abused his discretion by denying Soma's motion to compel jurisdictional discovery.

Disposition

affirmed