Featured Chrome Extensions:

Casey IRACs are produced by an AI that analyzes the opinion’s content to construct its analysis. While we strive for accuracy, the output may not be flawless. For a complete and precise understanding, please refer to the linked opinions above.

Keywords

plaintiffdefendantjurisdictionlitigationstatuteappealdue process
defendantjurisdictionlitigationstatuteappealwill

Related Cases

In re Corrugated Container Antitrust Litigation, 643 F.2d 195, 31 Fed.R.Serv.2d 632, 1981-1 Trade Cases P 63,966
View Case »
Chambers v. NASCO, Inc., 501 U.S. 32, 111 S.Ct. 2123, 115 L.Ed.2d 27, 59 USLW 4595, 19 Fed.R.Serv.3d 817
View Case »
Quintel Corp. v. Citibank, N.A., Not Reported in F.Supp., 1983 WL 2157
View Case »
Stone v. Powell, 428 U.S. 465, 96 S.Ct. 3037, 49 L.Ed.2d 1067
View Case »
Christy v. Saliterman, 288 Minn. 144, 179 N.W.2d 288
View Case »
Justia Law Link
LexisNexis Link
Westlaw Link
CourtListener Link
Oyez Link

Daynard v. Ness, Motley, Loadholt, Richardson & Poole, P.A., 290 F.3d 42

Facts

Richard A. Daynard, a law professor at Northeastern University, sued the Scruggs defendants for a share of the fees from tobacco litigation, claiming he was retained under an oral agreement. Daynard alleged that he provided significant assistance to both the Scruggs and Motley defendants in their joint venture against the tobacco industry, including legal theories and strategies that were central to their litigation efforts. The Motley defendants conceded personal jurisdiction, but the Scruggs defendants contested it, leading to the district court's dismissal of the case.

Daynard is a law professor at Northeastern University specializing in litigation against the tobacco industry. He sued the Motley and Scruggs defendants, claiming that, pursuant to an oral agreement, he is entitled to a portion of the fees that these firms have received or will receive from their successful tobacco litigation.

Issue

Whether a federal district court sitting in Massachusetts has specific personal jurisdiction over the Mississippi law firm Scruggs, Millette, Bozeman & Dent and its senior partner Richard Scruggs in a suit brought by Massachusetts law professor Richard A. Daynard for fees in tobacco litigation.

The issue on appeal is whether a federal district court sitting in Massachusetts has specific personal jurisdiction over a suit brought by Richard A. Daynard, a Massachusetts law professor, for fees in the tobacco litigation, against the Mississippi law firm of Scruggs, Millette, Bozeman & Dent, and Richard Scruggs, a senior partner (“Scruggs defendants”).

Rule

To establish personal jurisdiction, a plaintiff must show that the state's long-arm statute grants jurisdiction and that the exercise of jurisdiction is consistent with constitutional due process requirements.

To establish personal jurisdiction, Daynard must show that the Massachusetts long-arm statute grants jurisdiction and, if it does, that the exercise of jurisdiction under the statute is consistent with the constitution.

Analysis

The court concluded that the relationship between the Scruggs defendants and the Motley defendants was sufficient to impute the Motley defendants' contacts with Massachusetts to the Scruggs defendants. The court found that Daynard's allegations, if credited, demonstrated a joint venture or agency relationship that justified the attribution of contacts for the purpose of establishing personal jurisdiction.

We conclude that some of these contacts may be imputed. The next question is whether the sum of any imputed and direct contacts permits the court to exercise personal jurisdiction over the Scruggs defendants consistent with the Constitution. We conclude that these contacts suffice under Supreme Court law, e.g., Burger King, 471 U.S. at 471–87, 105 S.Ct. 2174; Int'l Shoe, 326 U.S. 310, 66 S.Ct. 154, 90 L.Ed. 95, and the law of this circuit, e.g., Noonan, 135 F.3d at 90; Foster–Miller, 46 F.3d at 144.

Conclusion

The Court of Appeals reversed the district court's dismissal for lack of personal jurisdiction and remanded the case for further proceedings, holding that the Scruggs defendants were subject to specific personal jurisdiction based on their contacts with Massachusetts.

We conclude that the Scruggs defendants' contacts with Massachusetts, particularly those contacts of the Motley defendants properly attributed to the Scruggs defendants, suffice to permit personal jurisdiction over the Scruggs defendants consistent with the Massachusetts long-arm statute and the Fourteenth Amendment of the Constitution.

Who won?

Richard A. Daynard prevailed in the appeal, as the court found that he made a prima facie showing of specific personal jurisdiction over the Scruggs defendants based on their contacts with Massachusetts.

Daynard is a resident and citizen of the Commonwealth of Massachusetts. He is, and has been for over thirty years, a law professor at Northeastern University School of Law, located in Massachusetts.

You must be