Dean Angelle et al v. CVS Health Corp et al

CourtDistrict Court, W.D. Louisiana
DecidedMarch 3, 2026
Docket6:25-cv-01113
StatusUnknown

This text of Dean Angelle et al v. CVS Health Corp et al (Dean Angelle et al v. CVS Health Corp et al) is published on Counsel Stack Legal Research, covering District Court, W.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dean Angelle et al v. CVS Health Corp et al, (W.D. La. 2026).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA LAFAYETTE DIVISION

DEAN ANGELLE ET AL CASE NO. 6:25-CV-01113

VERSUS JUDGE ROBERT R. SUMMERHAYS C V S HEALTH CORP ET AL MAGISTRATE JUDGE CAROL B. WHITEHURST

REPORT AND RECOMMENDATION

Before the Court is Defendant, CVS Health Corporation’s Motion to Dismiss for Lack of Personal Jurisdiction. (Rec. Doc. 8). Plaintiffs did not oppose the motion. The motion was referred to the undersigned magistrate judge for review, report, and recommendation in accordance with the provisions of 28 U.S.C. §636 and the Court’s standing orders. Considering the evidence, the law, and the parties’ arguments, and for the following reasons, the Court recommends that CVS Health’s motion be granted. Facts and Procedural History Plaintiffs, individually and on behalf of others similarly situated, filed this putative class action in state court against CVS Health Corp., CVS Pharmacy, Inc., Caremark PCS Health LLC, who they refer to collectively as “CVS/Caremark,” inter alia asserting claims under Louisiana’s Unfair Trade Practices Act (LUPTA) based on alleged CVS text messages and emails to Louisiana CVS customers urging them to contact their state representatives to vote against pending legislation (House Bill

358) that would impact CVS/Caremark. (Rec. Doc. 2-1, 2-2). CVS Health Corp., a non-Louisiana parent company of other CVS entities, filed the instant motion to dismiss on the grounds that the Court lacks personal jurisdiction.

Law and Analysis I. Personal Jurisdiction F.R.C.P. Rule 12(b)(2) is the vehicle by which a non-resident defendant may challenge the court’s personal jurisdiction over him. Plaintiffs bear the burden of

demonstrating jurisdiction by presenting facts sufficient to constitute a prima facie case of jurisdiction. Johnson v. TheHuffingtonPost.com, Inc., 21 F.4th 314, 317 (5th Cir. 2021), cert. denied, 143 S. Ct. 485, 214 L. Ed. 2d 277 (2022); Central Freight

Lines Inc. v. APA Transport Corp., 322 F.3d 376, 380 (5th Cir.2003). In determining whether jurisdiction exists, the court must accept the plaintiff’s uncontroverted, non- conclusory allegations of fact. Johnson, 21 F.4th at 317. The court is not required to credit conclusory allegations, even if left uncontroverted. Panda Brandywine Corp.

v. Potomac Elec. Power Co., 253 F.3d 865, 868-69 (5th Cir. 2001). In determining whether personal jurisdiction is proper, a district court sitting in diversity, as in this case, applies the law of the forum state in which it sits. Fed.

R. Civ. P. 4(e). The Louisiana Long-Arm Statute provides that this Court may exercise personal jurisdiction over any nonresident so long as the basis for such jurisdiction is consistent with the United States Constitution. Fed. R. Civ. P. 4(e).

Consequently, the limits of the Louisiana Long-Arm statue are coextensive with the limits of constitutional due process. Alonso v. Line, 02-2644 (La. 05/20/03), 846 So.2d 745, cert. denied, 540 U.S. 967 (2003); Petroleum Helicopters, Inc. v. Avco

Corp., 513 So.2d 1188, 1192 (La. 1987). This Court need only determine whether subjecting Defendants to suit in Louisiana would be consistent with the Due Process Clause of the Fourteenth Amendment. See, e.g., Walk Haydel & Associates, Inc. v. Coastal Power Production Co., 517 F.3d 235, 242-43 (5th Cir. 2008).

The exercise of personal jurisdiction over a nonresident defendant satisfies due process when: (1) the defendant has purposefully availed itself of the benefits and protections of the forum state by establishing minimum contacts with that state,

and (2) the exercise of jurisdiction does not offend traditional notions of fair play and substantial justice. Latshaw v. Johnston, 167 F.3d 208, 211 (5th Cir.1999). In other words, due process is satisfied when the defendant’s connection with Louisiana is such that the defendant should reasonably anticipate being haled into court in

Louisiana. Id. Minimum contacts may give rise to either specific jurisdiction or general jurisdiction. General personal jurisdiction exists when a defendant’s affiliations with

the forum state are so continuous and systematic as to render the defendant essentially at home there even if the cause of action did not arise from or relate to the defendant’s purposeful contacts with the forum. Freudensprung v. Offshore

Tech. Servs., Inc., 379 F.3d 327, 343 (5th Cir. 2004). Specific jurisdiction applies when a nonresident defendant has purposefully directed its activities at the forum state and the litigation results from alleged injuries that arise out of or relate to those

activities. Walk Haydel, 517 F.3d at 243. Whether specific jurisdiction exists is a three-step inquiry. First, the court must determine whether the defendant has minimum contacts with the forum state or, in other words, whether the defendant has purposefully directed its activities toward the forum state or purposefully availed

itself of the privileges of conducting activities there. Nuivo Pignone, SpA v. STORMAN ASIA M/V, 310 F.3d 374, 378 (5th Cir.2002). Random, fortuitous, or attenuated contacts are insufficient. Moncrief Oil Int'l v. OAO Gazprom, 481 F.3d

309, 311 (5th Cir.2007). However, “[a] single act by a defendant can be enough to confer personal jurisdiction if that act gives rise to the claim being asserted.” Lewis v. Fresne, 252 F.3d 352, 358–59 (5th Cir.2001). Second, the court must determine whether the plaintiff’s cause of action arises

out of or results from the defendant’s contacts with the forum. Nuivo Pignone, 310 F.3d at 378. Finally, if the plaintiff satisfies the first two prongs, the burden shifts to the defendant to defeat jurisdiction by showing that the forum state’s exercise of jurisdiction would be unfair or unreasonable. Seiferth v. Helicopteros Atuneros, Inc., 472 F.3d 266, 271 (5th Cir.2006).

II. CVS Health’s Lack of Contacts CVS Health submitted the declaration of its representative, Thomas S. Moffatt, who declared that CVS is a holding company whose primary functions are

to issue stock and file SEC reports. (Rec. Doc. 8-2, ¶4). It is a Delaware corporation with its principal place of business in Rhode Island and is a distinct entity from other CVS defendants in the suit. (¶5; 11). It has no offices, businesses, employees, operations, or presence in Louisiana. (¶6-10). CVS Health’s status as parent

company of other defendant CVS entities does not amount to contacts sufficient to impute or confer jurisdiction. Kelly v. Syria Shell Petroleum Dev. B.V., 213 F.3d 841, 857 (5th Cir. 2000). Plaintiffs offered no countervailing evidence to suggest

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Related

Latshaw v. Johnston
167 F.3d 208 (Fifth Circuit, 1999)
Kelly v. Syria Shell Petroleum Development B.V.
213 F.3d 841 (Fifth Circuit, 2000)
Nuovo Pignone S P A v. Storman Asia MV
310 F.3d 374 (Fifth Circuit, 2002)
Central Freight Lines Inc. v. APA Transport Corp.
322 F.3d 376 (Fifth Circuit, 2003)
Freudensprung v. Offshore Technical Services, Inc.
379 F.3d 327 (Fifth Circuit, 2004)
Seiferth v. Helicopteros Atuneros, Inc.
472 F.3d 266 (Fifth Circuit, 2006)
Moncrief Oil International Inc. v. OAO Gazprom
481 F.3d 309 (Fifth Circuit, 2007)
Petroleum Helicopters, Inc. v. Avco Corp.
513 So. 2d 1188 (Supreme Court of Louisiana, 1987)
Alonso v. Line
846 So. 2d 745 (Supreme Court of Louisiana, 2003)
Johnson v. TheHuffingtonpost.com
21 F.4th 314 (Fifth Circuit, 2021)

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