Anna Fernandez Willis v. Riley Herbert Willis, III

Summary

The United States District Court for the District of Maine dismissed the plaintiff’s assault-related action without prejudice for lack of personal jurisdiction. The court held that the defendant’s alleged conduct occurred in Alabama, and the plaintiff’s subsequent move to Maine and resulting injuries there did not establish sufficient contacts or foreseeability for Maine jurisdiction.

Holdings

1. Before granting default judgment, the court has an affirmative duty to ensure that it possesses personal jurisdiction over the absent defendant; a default judgment entered without personal jurisdiction would be void.
2. Maine lacked personal jurisdiction over Defendant because the alleged tortious conduct occurred in Alabama, the parties resided there when it occurred, and Plaintiff's subsequent move to Maine did not establish that Defendant purposefully established contacts with Maine or could reasonably anticipate being sued there.

Questions Presented

1. Whether the court could enter default judgment without first establishing personal jurisdiction over Defendant.
2. Whether Defendant had sufficient minimum contacts with Maine under Maine's long-arm statute and the Due Process Clause to support personal jurisdiction.
3. Whether Plaintiff's subsequent move to Maine, anticipated medical consequences there, and family ties to Maine established that Defendant could reasonably anticipate being sued in Maine.

Disposition

dismissed