Brittany Widmayer, et al. v. Otis Worldwide Corporation

Summary

The United States District Court for the District of Nevada granted Plaintiffs’ motion for jurisdictional discovery in a dispute concerning whether Otis Elevator’s Nevada contacts may be imputed to Otis Worldwide Corporation under an alter ego theory. The court held that general and specific jurisdiction are alternative bases for personal jurisdiction and that Daimler AG v. Bauman does not preclude alter ego-based general jurisdiction, while limiting discovery at this stage to interrogatories and requests for production.

Holdings

1. General and specific personal jurisdiction are alternative bases for personal jurisdiction; a plaintiff need not establish both.
2. Daimler AG v. Bauman does not preclude an argument that general personal jurisdiction may be established through an alter ego theory.
3. Plaintiffs were entitled to limited jurisdictional discovery concerning the potential unity of interest between Otis Elevator and Otis Worldwide Corporation.

Questions Presented

1. Whether general and specific personal jurisdiction must both be established to support jurisdiction over Defendant.
2. Whether Daimler AG v. Bauman precludes reliance on an alter ego theory to establish general personal jurisdiction.
3. Whether Plaintiffs were entitled to jurisdictional discovery concerning the potential alter ego relationship between Otis Elevator and Otis Worldwide Corporation.

Disposition

other