State ex rel. Cedar Crest Apartments, LLC and Peterson Properties, Inc. d/b/a The Peterson Companies v. The Honorable Jack Grate

Summary

The Supreme Court of Missouri made permanent a preliminary writ of prohibition, holding that Missouri courts lacked personal jurisdiction over two Kansas business entities sued for injuries arising from an accident in Kansas. The court concluded that the entities were not at home in Missouri for purposes of general jurisdiction and that the plaintiff’s claims did not arise from their Missouri contacts for purposes of specific jurisdiction. The court also rejected imputing the Missouri contacts of a related corporation to the relators and denied jurisdiction-related discovery.

Holdings

1. Missouri courts lacked general personal jurisdiction over Cedar Crest and Peterson Properties because neither entity was incorporated in Missouri or maintained its principal place of business there, and their Missouri contacts did not make Missouri an exceptional surrogate for their corporate home.
2. Missouri courts lacked specific personal jurisdiction because Martinez failed to show that his claims arose out of or were connected to any Missouri contact of either relator.
3. A corporation does not become the agent of another corporation merely because it owns the other corporation, and the Missouri contacts of a corporate parent or managing member cannot be imputed to out-of-state subsidiaries or related entities merely because of that relationship.
4. Martinez was not entitled to jurisdiction-related discovery because his pleadings contained only boilerplate allegations and legal conclusions, and he did not respond with evidence or facts establishing the relators' Missouri contacts after they contested jurisdiction.

Questions Presented

1. Whether Missouri courts could exercise general personal jurisdiction over the Kansas corporate relators based on their Missouri registration, business activities, lawsuits, and rental property.
2. Whether Missouri courts could exercise specific personal jurisdiction over the relators when Martinez's Kansas injury and claims did not arise out of their Missouri contacts.
3. Whether the Missouri contacts of J.A. Peterson Enterprises, Inc. could be imputed to the relators based on agency, ownership, or a parent-subsidiary relationship.
4. Whether Martinez was entitled to jurisdiction-related discovery despite failing to establish personal jurisdiction from the pleadings and evidence.

Disposition

writ_granted