Ruiz-Paramo v. Aroma360, LLC

Summary

The United States District Court for the District of Colorado denied without prejudice Plaintiff Dania Ruiz-Paramo’s renewed motion for default judgment against Aroma360, LLC. Although the court found that service of process was proper, it concluded that the complaint and supporting materials did not establish personal jurisdiction over the Florida-based defendant because they showed only a single online sale to a Colorado resident. The court permitted the plaintiff to potentially plead additional facts supporting specific jurisdiction.

Holdings

1. Service was proper under Federal Rule of Civil Procedure 4(h)(1)(B) because the second process-server affidavit identified Collester as an agent authorized by appointment to receive service of process.
2. The court had subject matter jurisdiction under 28 U.S.C. § 1331 because plaintiff's claim arose under federal law.
3. Plaintiff did not establish general personal jurisdiction over Aroma360 in Colorado because the complaint alleged that Aroma360 was registered and had its principal place of business in Florida and alleged no facts showing that Aroma360 was essentially at home in Colorado.
4. Plaintiff did not establish specific personal jurisdiction over Aroma360 because the complaint and supporting materials showed only one online sale to a Colorado resident, which was insufficient to establish the necessary minimum contacts.
5. The renewed motion for default judgment was denied without prejudice because plaintiff failed to plead sufficient facts establishing personal jurisdiction over Aroma360.

Questions Presented

1. Whether plaintiff properly served Aroma360, LLC under Federal Rule of Civil Procedure 4(h)(1)(B).
2. Whether the court had subject matter jurisdiction over plaintiff's federal CCARDA claim.
3. Whether the pleaded facts established general or specific personal jurisdiction over Aroma360 in Colorado.
4. Whether plaintiff was entitled to default judgment after the Clerk entered default.

Disposition

other