Scott Neil v. Union Pacific Railroad Company; TTX Company; and Trinity Industry Leasing Company

Summary

The United States District Court for the District of Utah granted Trinity Industry Leasing Company’s motion to dismiss Scott Neil’s negligence and gross-negligence claims for lack of personal jurisdiction. The court concluded that Trinity was not subject to general jurisdiction in Utah and had not purposefully directed activities toward Utah sufficient to support specific jurisdiction. The court found that Trinity’s ownership and lease of the railcar, without control over its subsequent location or use, did not establish the required minimum contacts.

Holdings

1. Neil did not establish general personal jurisdiction because Trinity was not incorporated in Utah, did not have its principal place of business in Utah, and had no other Utah contacts sufficient to render it at home there.
2. Neil did not establish specific personal jurisdiction because Trinity did not purposefully direct activities toward Utah, did not control the railcar's location or use after delivering it in Texas, and merely owning and leasing a railcar that later traveled to Utah did not establish the required minimum contacts.
3. Neil could not rely solely on the complaint's disputed allegations after Trinity specifically rebutted them by declaration; because he submitted no affidavits or other evidence, the court was not required to resolve the disputed management and maintenance allegations in his favor.

Questions Presented

1. Whether the court could exercise general personal jurisdiction over Trinity based on its ownership and leasing of the railcar.
2. Whether the court could exercise specific personal jurisdiction over Trinity based on the railcar's presence in Utah and Neil's injury there.
3. Whether Neil made a prima facie showing of personal jurisdiction after Trinity rebutted portions of the complaint's jurisdictional allegations with a declaration.

Disposition

dismissed