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Matos v. Nextran, Inc.

District Court of the Virgin Islands · 2009 · Civil Procedure

Civil ProcedurePersonal JurisdictionLong-Arm StatuteSpecific JurisdictionRule 12(b)(2)personal jurisdictionVirgin Islands long-arm statutetransacting business

Facts

Mr. Matos was injured in St. Thomas when a concrete truck he was driving rolled over. Plaintiffs alleged that the truck was manufactured and sold by Nextran and asserted tort and warranty claims. Jurisdictional discovery showed that Nextran had sold at least thirteen trucks to Virgin Islands residents for use in the territory, sent those trucks to customers there, tailored truck specifications to Virgin Islands customers, and sent representatives and mechanics to the Virgin Islands to support and service its products. Nextran's Rule 30(b)(6) witness also testified that an invoice existed for the truck involved in the accident and identified it as the truck in question.

Issue

Whether the District Court of the Virgin Islands could exercise personal jurisdiction over Nextran on plaintiffs' claims arising from the truck accident. More specifically, the question was whether Nextran was reachable under the Virgin Islands long-arm statute and whether exercising specific jurisdiction over Nextran comported with due process.

Rule

When no evidentiary hearing is held on a Rule 12(b)(2) motion, the plaintiff need only make a prima facie showing of personal jurisdiction, with allegations taken as true and factual disputes resolved in the plaintiff's favor. Under the Virgin Islands long-arm statute, "transacting business" requires purposeful activity in the territory and may be satisfied by even a single act, including a contract with a Virgin Islands resident to be performed at least in part in the Virgin Islands. Specific jurisdiction requires that the defendant purposefully direct activities at the forum, that the claim arise out of or relate to those forum-related activities, and that the exercise of jurisdiction comport with traditional notions of fair play and substantial justice.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

A Nevada manufacturer, Silver Mesa Equipment, moved to dismiss for lack of personal jurisdiction in the District Court of the Virgin Islands after being sued over an allegedly defective paving machine that injured Omar Lewis in St. Croix. No evidentiary hearing was requested. In opposition, Lewis submitted deposition excerpts showing Silver Mesa sold eight machines to Virgin Islands contractors, shipped them to St. Croix and St. Thomas, and once sent a technician there to service one.

What showing must Lewis make at this stage to defeat the motion?

Explanation. When the court decides a Rule 12(b)(2) motion without an evidentiary hearing, the plaintiff need only make a prima facie showing of personal jurisdiction. The court takes the plaintiff’s allegations as true and draws factual disputes in the plaintiff’s favor. The majority opinion applied that standard even after jurisdictional discovery. (Derived from Matos v. Nextran, Inc. (n.d.).)