Alliant, LLC v. John “Esty” McCoy, Fluid Charge, LLC, Leesburg Pike Partners, LLC (Maryland), Zach Lapole, Gage Evans, Christy Milton, and Tracer Payments, LLC

Summary

The United States District Court for the District of Idaho considers defendants’ motions to dismiss Alliant, LLC’s claims for lack of personal jurisdiction. The court concludes that Alliant failed to establish purposeful direction or purposeful availment, or that the claims arose from defendants’ Idaho-related activities. The court grants the motions and dismisses the claims without prejudice.

Holdings

1. The court lacked specific personal jurisdiction over McCoy, Fluid Charge, LLC, and Leesburg Pike Partners, LLC because Alliant failed to show that their alleged tortious conduct was expressly aimed at Idaho or that the claims arose out of or related to Idaho-directed activity.
2. The court lacked specific personal jurisdiction over McCoy for the implied-contract, fraudulent-inducement, and unjust-enrichment claims arising from the $103,000 loan.
3. The court lacked specific personal jurisdiction over Evans and Lapole because Alliant failed to show that either defendant expressly aimed the alleged tortious conduct at Idaho or that the claims arose out of Idaho-directed activity.

Questions Presented

1. Whether the District of Idaho had specific personal jurisdiction over McCoy, Fluid Charge, LLC, and Leesburg Pike Partners, LLC for the asserted tort claims.
2. Whether the District of Idaho had specific personal jurisdiction over McCoy for the implied-contract, fraudulent-inducement, and unjust-enrichment claims arising from the $103,000 loan transaction.
3. Whether the District of Idaho had specific personal jurisdiction over Evans and Lapole for the asserted tort and trade-secret claims.
4. Whether the District of Idaho had specific personal jurisdiction over Milton and Tracer Payments, LLC for claims arising from Lapole's alleged disclosure and use of Alliant's proprietary information.
5. Whether the action should be transferred under 28 U.S.C. § 1631 rather than dismissed for lack of jurisdiction.