Gary Roeber v. Hilton Worldwide Holdings, Inc., 4th Generation Development Inc., and Keenan Management, LLC

Summary

The United States District Court for the Northern District of Illinois granted defendants’ motions to dismiss Gary Roeber’s negligence action for lack of personal jurisdiction. The court held that Hilton Worldwide’s subsidiaries’ contacts could not be imputed to Hilton Worldwide and that none of the defendants had sufficient Illinois contacts supporting general or specific jurisdiction. The dismissals were without prejudice.

Holdings

1. The court lacked general personal jurisdiction over Hilton Worldwide because the evidence showed that it was a Delaware corporation with its principal place of business in Virginia, had no employees or properties in Illinois, and the plaintiff failed to establish that its subsidiaries' Illinois contacts were attributable to Hilton Worldwide.
2. The plaintiff failed to make a prima facie showing of specific personal jurisdiction over Hilton Worldwide because nationwide advertising, an interactive booking website, and a generally available rewards program did not establish purposeful availment of Illinois, and the alleged Illinois conduct did not give rise to or relate to the plaintiff's injury in Nebraska.
3. The plaintiff failed to make a prima facie showing of specific personal jurisdiction over 4th Generation or Keenan Management because the defendants' alleged participation in the Hilton ecosystem, the presence of Illinois guests at the Nebraska hotel, and the hotel's availability through Hilton systems did not show purposeful targeting of Illinois.
4. Dismissal for lack of personal jurisdiction is without prejudice because the plaintiff may pursue the action in another venue.

Questions Presented

1. Whether the court could exercise general personal jurisdiction over Hilton Worldwide based on its alleged nationwide brand, Illinois contacts, and alleged ownership or control of Hilton-branded hotels.
2. Whether the court could exercise specific personal jurisdiction over Hilton Worldwide based on alleged advertising, its booking website, its rewards program, or the booking of a Nebraska hotel by an Illinois resident.
3. Whether the court could exercise specific personal jurisdiction over 4th Generation and Keenan Management based on the Hilton corporate ecosystem, Illinois guests staying at the Nebraska hotel, or the hotel's integration with Hilton's booking and rewards systems.
4. Whether dismissal for lack of personal jurisdiction should be with prejudice.

Disposition

dismissed