Tuesday, May 25, 2021

Eastern District Court Holds That the Long Arm of the Law Can Only Go So Far in Terms of Personal Jurisdiction

In the case of Ruffing v. Wipro Ltd., No. 20-5545 (E.D. Pa. March 29, 2021 Bartle, J.), the Eastern District Federal Court granted a Partial Motion to Dismiss on jurisdictional grounds.   

In this employment action matter, the court found that non-Pennsylvania Plaintiffs lacked personal jurisdiction over a Defendant, which was a non-Pennsylvania company because the action involved only the non-Pennsylvania conduct of the Defendant. 

Notably, the court ruled that Pennsylvania cannot constitutionally subject an out-of-state Defendant to general jurisdiction in Pennsylvania simply based upon the fact that the company may have registered to do business in Pennsylvania.   

The Eastern District Court noted that the U.S. Supreme Court in Daimler AG v. Bauman, 571 U.S. 117, 125 (2014) prohibited such an expansive scope of general jurisdiction rules.   

The court in this Ruffing case noted that the United States Supreme Court decision in Bauman would become virtually meaningless if a state could mandate the exercise of general personal jurisdiction over every entity that did business within its border simply because that company had registered to do business in the state.   The Eastern District Court stated that Third Circuit precedent to the contrary was no longer valid since the United States Supreme Court handed down its decision in Bauman.   

Rather, a corporation must be “at home” in a jurisdiction to be subject to general jurisdiction in that state.   

Anyone wishing to review a copy of this decision may click this LINK. The companion Order can be reviewed HERE.

I send thanks to Attorney James M. Beck of the Philadelphia law office of the Reed Smith law firm for bringing this case to my attention.   

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