Rose v. Firstar Bank

Summary

The Supreme Court of Rhode Island held that Rhode Island courts lacked personal jurisdiction over an Ohio bank serving as trustee of an Ohio trust. The bank's mailing of trust statements and checks and occasional trust-related telephone communications to Rhode Island beneficiaries did not constitute purposeful availment of Rhode Island's benefits and protections, and the beneficiaries' mismanagement claims did not arise from contacts with the state. The court granted certiorari, quashed the Superior Court's order, and remanded for dismissal for lack of personal jurisdiction.

Holdings

1. Rhode Island lacked specific personal jurisdiction over Firstar because Firstar did not purposefully avail itself of the privilege of conducting activities in Rhode Island, and the beneficiaries' trust-mismanagement claims did not arise out of Firstar's Rhode Island contacts.
2. The Court did not decide whether Firstar's contacts were systematic and purposeful enough to establish general personal jurisdiction because the beneficiaries conceded that they were not asserting general jurisdiction.
3. The Court concluded that Rhode Island could not exercise in rem jurisdiction over the Ohio trust on the alleged facts, but noted that the issue was not properly preserved because it had not been raised in the motion to dismiss or presented to the Superior Court.

Questions Presented

1. Whether Rhode Island courts had specific personal jurisdiction over an Ohio bank serving as trustee of an Ohio trust based on its mailing trust statements and checks and making occasional trust-related telephone calls to Rhode Island beneficiaries.
2. Whether Firstar purposefully availed itself of the privilege of conducting activities in Rhode Island by continuing to serve as trustee after a beneficiary relocated to Rhode Island.
3. Whether Rhode Island could exercise in rem jurisdiction over the Ohio trust.

Disposition

quashed