Theodore Justice v. Ally Financial, Inc., et al.

Summary

The United States District Court for the Eastern District of Michigan accepts and adopts the magistrate judge’s report and recommendation and grants Samsung Electronics America’s motion to dismiss for lack of personal jurisdiction under Federal Rule of Civil Procedure 12(b)(2). The court overrules the plaintiff’s objections concerning supplemental briefing, jurisdictional discovery, general jurisdiction, specific jurisdiction, and alleged misrepresentations. Samsung is dismissed without prejudice, and the case remains open as to the other defendants.

Holdings

1. The district court overruled Justice's objections and accepted and adopted the magistrate judge's report and recommendation because the objections were either meritless, insufficiently supported, or did not establish error.
2. Samsung was not subject to general personal jurisdiction in Michigan because Michigan was neither its place of incorporation nor its principal place of business, and the alleged continuous business activity did not make Samsung essentially at home there.
3. Samsung was not subject to specific personal jurisdiction in Michigan because, although it purposefully availed itself of Michigan's market, Justice's claims did not arise from or relate to Samsung's Michigan contacts and exercising jurisdiction would not be reasonable.
4. Justice was not entitled to jurisdictional discovery because he failed to make a prima facie showing of either general or specific personal jurisdiction.
5. The magistrate judge did not err by refusing to consider Justice's supplemental briefing because supplemental briefs were not permitted without court authorization under the applicable local rule.

Questions Presented

1. Whether the district court properly reviewed and adopted the magistrate judge's report and recommendation after overruling Justice's objections.
2. Whether Samsung was subject to general personal jurisdiction in Michigan.
3. Whether Samsung was subject to specific personal jurisdiction in Michigan based on its sales and distribution of similar products in Michigan.
4. Whether Justice was entitled to supplemental briefing or jurisdictional discovery.
5. Whether Samsung's alleged representations warranted Rule 11 sanctions.

Disposition

dismissed