Widman Immigration Law Firm, LLC v. Passage Inc. and Martin Basiri

Summary

The U.S. District Court for the District of Oregon grants Martin Basiri’s motion to dismiss for lack of personal jurisdiction. The court holds that Widman Immigration Law Firm, LLC failed to allege or demonstrate that Basiri personally purposefully directed activities toward Oregon, notwithstanding his position as an officer and director of Passage Inc. Basiri is dismissed without prejudice, while the case proceeds against Passage Inc.; the court permits the plaintiff to seek leave to amend if discovery reveals additional jurisdictional facts.

Holdings

1. The court lacked specific personal jurisdiction over Basiri because Widman Law failed to make a prima facie showing that Basiri, as opposed to Passage Inc., purposefully directed activities toward Oregon.
2. The fiduciary shield doctrine neither subjected Basiri to personal jurisdiction merely because of his association with Passage Inc. nor insulated him from jurisdiction for acts he personally committed on behalf of the corporation.
3. Jurisdictional discovery was not warranted because Widman Law offered only a mere hunch and bare allegations rather than controverted jurisdictional facts or a satisfactory factual showing requiring discovery.
4. Dismissal for lack of personal jurisdiction was without prejudice and did not adjudicate the merits.

Questions Presented

1. Whether Oregon could exercise specific personal jurisdiction over Martin Basiri based on his alleged involvement in Passage Inc.'s use of the PASSAGE mark and website.
2. Whether Basiri's status as a corporate officer insulated him from personal jurisdiction under the fiduciary shield doctrine.
3. Whether jurisdictional discovery or leave to amend was warranted after the complaint failed to establish personal jurisdiction over Basiri.

Disposition

dismissed