Covert v. Media Intercept, Inc.

Summary

The United States District Court for the District of Idaho held that it lacked specific personal jurisdiction over Media Intercept, Inc. in Trevor Covert’s claims concerning unpaid commissions and expenses following his termination. The court concluded that Media’s employment of Covert, who worked remotely from Idaho, its participation in an Idaho unemployment proceeding, and isolated business dealings with an Idaho company did not establish sufficient purposeful contacts with Idaho. Rather than dismissing the action, the court transferred it to the United States District Court for the Middle District of Florida under 28 U.S.C. § 1631.

Holdings

1. Media Intercept did not have sufficient minimum contacts with Idaho to support specific personal jurisdiction. Covert's residence and remote work in Idaho, Media's knowledge of those facts, its hiring and termination of Covert there, payments to him there, participation in his Idaho unemployment claim, and isolated dealings with Kit, Inc. did not establish purposeful availment or purposeful direction toward Idaho.
2. When a federal court lacks jurisdiction, 28 U.S.C. § 1631 authorizes transfer rather than dismissal when transfer is in the interest of justice and the action could have been brought in the transferee court. Transfer to the Middle District of Florida was warranted here.

Questions Presented

1. Whether the District of Idaho could exercise specific personal jurisdiction over Media Intercept, Inc. based on its employment relationship with an Idaho resident who worked remotely from Idaho, its payments and employment actions directed to Idaho, its participation in an Idaho unemployment proceeding, and isolated dealings with an Idaho company.
2. Whether, after finding personal jurisdiction lacking, the court should dismiss the action or transfer it to the Middle District of Florida under 28 U.S.C. § 1631.

Disposition

remanded