Argo Marketing Group, Inc. v. Sena

Superior Court of Maine·Decided October 3, 2017·No. ANDcv-17-98·Unpublished

Opinion

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STATE OF MAINE SUPERIOR COURT ANDROSCOGGIN, ss. CIVIL ACTION DOCKET NO. CV-17-98 ARGO MARKETING GROUP, INC., ) ) Plaintiff ) OCT 3 '17 AMl0:33 ) ANDRO SUPERIOR COURl V. ) ) ORDER ON DEFENDANT CATALINA SENA ) HEALTH LINE MARKETING, ) LLC'S MOTION TO DISMISS and ) ) HEALTH LINE MARKETING, LLC, ) ) Defendants. )

Before the Court is Defendant Health Line Marketing, LLC' s ("Health Line")

motion to dismiss pursuant to Maine Rule of Civil Procedure 12(b )(2). Plaintiff Argo

Marketing Group, Inc. (" Argo") objects.

I. Background

On or about April 12, 2016, Argo, a Maine corporation, and Health Line, a Florida

corporation, entered into an agreement whereby Argo would perform certain

telemarketing and customer services for Health Line's products. (Pl.'s Compl. <[ 4.) Argo

filed a complaint dated May 17, 2017 alleging the sum of $79,465.21 is due and owing

from Health Line under the agreement and that, despite demand, Health Line has failed

to pay these outstanding invoices. (PL's Compl.

Defendant Catalina Sena guaranteed the payment of all sums due to Argo from Health

Line and that Defendant Sena has likewise failed to pay the amount due. (PL's Compl.

<[

this motion, alleging the State of Maine does not have personal jurisdiction over Health

Line because Argo's complaint does not allege any actions between the parties occurred

in Maine, that Argo sold any of Health Line's products in Maine, or that Health Line

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otherwise transacts any business in Maine. (Mot. Dismiss 1-2.) On August 15, 2017, Argo

filed an objection to this motion and attached the affidavit of Nicole Morgan, the Director

of Client Services for Argo. In her affidavit, Morgan states that a representative of Health

Line reached out to Argo's Director of Business Development to discuss and finalize the

agreement made the basis of this lawsuit. (Morgan Aff. <[

services rendered by Argo to Health Line were made by wire to Argo's bank in Maine,

all communications from Health Line to Argo were directed to Argo's offices in Maine,

and the underlying agreement states the contractual relationship between the parties will

be governed by the laws of the State of Maine. (Morgan Aff. 'lI'lI 9-11.)

II. Discussion

"The proper exercise of personal jurisdiction in a Maine court hinges on the

satisfaction of two requirements: first, that the Maine Long-Arm Statute ... confers

personal jurisdiction on the court; and second, that the exercise of jurisdiction pursuant

to the long-arm statute complies with constitutional due process requirements." Jackson

v. Weaver, 678 A.2d 1036, 1038 (Me. 1996). Maine's long-arm jurisdiction statute, 14 M.R.S.

§ 704-A(l), provides that "[t]his section, to insure maximum protection to citizens of this

State, shall be applied so as to assert jurisdiction over nonresident defendants to the

fullest extent permitted by the due process clause of the United States Constitution, 14th

amendment." The statute further states, in relevant part:

Any person, whether or not a citizen or resident of this State, who in person or through an agent does any of the acts hereinafter enumerated in this section, thereby submits such person ... to the jurisdiction of the courts of this State as to any cause of action arising from the doing of any of such acts:

A. The transaction of any business within this State;

F. Contracting to supply services or things within this State .. ..

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14 M.R.S. § 704-A(2). Without question, Health Line subjected itself to Maine's long-arm

jurisdiction by transacting business within this state and by contracting with Argo to

provide services within this state.

In addition to satisfying the long-arm statute, in order for the state of Maine to

exercise jurisdiction over a non-resident defendant, the exercise of jurisdiction must

comport with the Due Process clauses of the Maine Constitution, Me. Const. art. I,§ 6-A,

and the United States Constitution, U.S. Const. amend. XIV, § 1. Maine courts have

developed a three-prong test to determine whether the exercise of personal jurisdiction

over a non-resident defendant is consistent with the requirements of due process. This

test requires that: 1) Maine has a legitimate interest in the subject matter of the

controversy; 2) the defendant, by its conduct, should reasonably have anticipated

litigating in Maine; and 3) the exercise of jurisdiction by Maine's courts comports with

traditional notions of fair play and substantial justice. Estate of Hoch v. Stifel, 2011 ME 24,

(Me. 1993). The plaintiff bears the burden of establishing that jurisdiction is proper under

the first two prongs of the test based on specific facts in the record. Cavers v. Houston

McLane Co., 2008 ME 164,

show that jurisdiction is improper under the third prong. See id. "The record must be

construed in the manner most favorable to the party asserting jurisdiction." Id.

As to the first prong, Maine has an interest in providing its citizens with a means

of redress against non-residents. Interstate Food Processing Corp., 622 A.2d at 1192.

Furthermore, Maine has an interest in regulating non-resident "parties who 'reach out

beyond one state and create continuing relationships and obligations with citizens of"'

Maine. Burger King Corp. v. Rudzewicz, 471 U.S. 462, 473 (1985); see Electronic Media Int'l v.

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Pioneer Commc'ns of Am., Inc., 586 A.2d 1256, 1259 (Me. 1991). In this case, a representative

of Health Line reached out to a representative of Argo to negotiate and contract for

services that were provided entirely within the state of Maine. Because Health Line

reached out to a Maine corporation to create this contractual relationship, thereby

incurring continuing obligations to Maine citizens, Maine has a legitimate interest in the

subject matter of this controversy.

Regarding the second prong, for a foreign corporation to be subject to Maine's

jurisdiction, the corporation must have sufficient conta~ts with Maine to make it

reasonable to require the corporation to defend the suit here. Interstate Food Processing

Corp., 622 A.2d at 1192. The defendant's contacts may not result solely from the unilateral

activity of the plaintiff; rather, the defendant must purposefully avail itself of "the

privilege of conducting activities within [Maine], thus invoking the benefits and

protections of its laws." Burger King Corp., 471 U.S. at 474-75; Interstate Food Processing

Corp., 622 A.2d at 1192. This requirement is met when a defendant purposefully directs

his activities at Maine residents by deliberately engaging in significant activities in Maine

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