Summary
The court grants defendants’ renewed motion to dismiss for lack of personal jurisdiction in an action asserting Tennessee-law claims arising from the plaintiff’s former romantic relationship and alleged interference with his employment. The court holds that the plaintiff’s allegations that defendants contacted his former employer are speculative and insufficient to establish specific personal jurisdiction. In the interest of justice, the court transfers the action to the U.S. District Court for the Southern District of Alabama under 28 U.S.C. § 1631.
Topics
Practice areas
Questions Presented
- Whether the Eastern District of Tennessee had specific personal jurisdiction over Oksana Kristen Singh and Iqbal Singh under Tennessee's long-arm statute and the Due Process Clause.
- Whether the action should be dismissed without prejudice or transferred under 28 U.S.C. § 1631 after the court determined that it lacked personal jurisdiction.
Holdings
- The court lacked specific personal jurisdiction over Oksana Singh and Iqbal Singh because Mattson's conclusory and speculative allegation that they contacted LMU to cause his termination was unsupported by specific facts, and their other identified Tennessee contacts did not give rise to his claims.
- The action should be transferred to the United States District Court for the Southern District of Alabama rather than dismissed because transfer was in the interest of justice and that court was a forum in which the action could have been brought.
Key quotations
“A plaintiff cannot establish personal jurisdiction over a defendant based on speculation alone.” (III)
“It simply cannot be the case that a plaintiff can hail his ex-girlfriend’s father into an out-of-state court on nothing more than an allegation that “my ex’s father doesn’t like me, so he must have caused the harm I suffered in the forum.”” (III)
Factual background
Mattson, an adjunct instructor at Lincoln Memorial University in Tennessee, dated Oksana Singh for more than two years. After their relationship ended, Oksana filed a Petition from Abuse in Alabama that allegedly contained false accusations and stated that Mattson may have been fired from LMU; Mattson was terminated ten days later. Mattson alleged that Oksana and her father, Iqbal Singh, contacted LMU with false and defamatory statements to cause his termination, but he identified no recipient, statement, or other facts supporting that allegation.
Procedural history
Mattson filed suit in the Eastern District of Tennessee asserting Tennessee-law claims arising from his termination by Lincoln Memorial University. After defendants submitted affidavits disputing their Tennessee contacts, Mattson opposed the renewed Rule 12(b)(2) motion with his own affidavit. The court resolved the motion on the papers, found that Mattson failed to make a prima facie showing of specific personal jurisdiction, and transferred the action to the Southern District of Alabama in the interest of justice.
Remand instructions
The Clerk was directed to transfer the action to the United States District Court for the Southern District of Alabama and close the Eastern District of Tennessee file. The action was transferred rather than dismissed.