Rilley v. MoneyMutual LLC

Brief Fact Summary.

MoneyMutual operated  website that matched individuals with lenders for short term “payday loans.” Respondents, Minnesota residents, filed a class action complaint in Minnesota state court against MoneyMutual  alleging that MoneyMutual engaged in illegal and tortious conduct in connection with its loan business. MoneyMutual moved to dismiss the complaint for lack of personal jurisdiction. The district court upheld jurisdiction and the appellate court affirmed.

Synopsis of Rule of Law.

E-mail based contacts with a forum can provide a basis for personal jurisdiction if the sender knew or should have known that the recipient was located in a particular forum and would receive the email there.

Facts.

Four Minnesota residents filed a class action complaint against MoneyMutual, the operator of a  website that matched individuals with lenders for short term “payday loans.” Respondents alleged that MoneyMutual engaged in illegal and tortious conduct in connection with its loan business because: the terms of the loans were illegal under state law, MoneyMutual matched applicants with unlicensed lenders, and the website’s advertising contained misrepresentations that violated state law.  MoneyMutual moved to dismiss the complaint for lack of personal jurisdiction. The district court upheld jurisdiction and the appellate court affirmed.

Issue.

Did the lower courts err in upholding personal jurisdiction over MoneyMutual in Minnesota?

Held.

No. Jurisdiction was properly exercised over MoneyMutual, based on its commercial solicitations within Minnesota.

Discussion.

Traditional minimum contacts analysis considers the quantity, nature, and quality of contacts, and whether they establish the defendant’s substantial connection with and purposeful availing of a forum. Here:

• MoneyMutual’s solicitation of and transactions with over 1000 individuals in Minnesota demonstrated a purposeful direction of conduct in Minnesota;
• MoneyMutual’s national television advertisements seen in Minnesota were insufficient to form a basis for jurisdiction
• Use of Google AdWords advertising that targeted Minnesotans was a relevant contact for the purpose of minimum contacts analysis.