DeJames v. Magnificence Carriers

Brief Fact Summary.

DeJames (Plaintiff) sued Hitachi (Defendant) in federal court in New Jersey, alleging that Defendant’s contacts throughout the United States could be aggregated to satisfy the minimum contacts required for personal jurisdiction under the state long-arm statute

Synopsis of Rule of Law.

Without some statutory authority allowing for service of process, a federal court cannot look to a defendant’s contacts throughout the United States and aggregate them in order to allow it to exercise personal jurisdiction.

Facts.

Plaintiff sued Defendant after being injured on a cargo ship, claiming that Defendant’s defective work on the ship caused his injuries. Plaintiff filed in federal district court in New Jersey and Defendant moved to dismiss the complaint for lack of personal jurisdiction as Defendant had no office or agent in New Jersey and argued that it did not have the minimum contacts with New Jersey required by that state’s long-arm statute. Plaintiff argued that Defendant’s contacts throughout the United States could be aggregated to satisfy the minimum contacts required.

Issue.

Can a defendant’s contacts throughout the nation be aggregated to allow for a federal court to exercise personal jurisdiction?

Held.

(Cohen, Sr. J.) No. Without some statutory authority allowing for service of process, a federal court cannot look to a defendant’s contacts throughout the United States and aggregate them in order to allow it to exercise personal jurisdiction. Federal Rule of Civil Procedure 4(e) [now Fed. R. Civ. Pro. 4(k)(1)(A)] allows a court to exercise personal jurisdiction through a state’s long-arm statute only when the in-state activities of the defendant are substantial enough to meet the minimum contacts required for personal jurisdiction in a state court action. While national contacts may be considered when the basis for personal jurisdiction is not a state long-arm statute, they are not relevant here. Defendant had insufficient contacts in New Jersey to allow the federal court to assert personal jurisdiction. Motion granted.

Discussion.

Congress has not passed a federal statute that would authorize nationwide service of process. Therefore, a federal court’s power to exercise personal jurisdiction is limited by the Federal Rules of Civil Procedure, as in this case.