Doucet v. FCA US LLC

CourtMassachusetts Supreme Judicial Court
DecidedJune 8, 2023
DocketSJC 13354
StatusPublished

This text of Doucet v. FCA US LLC (Doucet v. FCA US LLC) is published on Counsel Stack Legal Research, covering Massachusetts Supreme Judicial Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Doucet v. FCA US LLC, (Mass. 2023).

Opinion

NOTICE: All slip opinions and orders are subject to formal revision and are superseded by the advance sheets and bound volumes of the Official Reports. If you find a typographical error or other formal error, please notify the Reporter of Decisions, Supreme Judicial Court, John Adams Courthouse, 1 Pemberton Square, Suite 2500, Boston, MA, 02108-1750; (617) 557- 1030; SJCReporter@sjc.state.ma.us

SJC-13354

AMY DOUCET1 & another2 vs. FCA US LLC3 & another.4

Essex. February 8, 2023. - June 8, 2023.

Present: Budd, C.J., Lowy, Cypher, Kafker, Wendlandt, & Georges, JJ.

Jurisdiction, Personal, Long-arm statute, Nonresident. Due Process of Law, Jurisdiction over nonresident. Practice, Civil, Motion to dismiss.

Civil action commenced in the Superior Court Department on May 17, 2021.

A motion to dismiss was heard by Janice W. Howe, J.; a motion for reconsideration was considered by her, and entry of separate and final judgment was ordered by her.

The Supreme Judicial Court on its own initiative transferred the case from the Appeals Court.

1 As guardian of Paul Gregory Doucet.

2 Denise Sutton, as guardian of Paul Gregory Doucet.

3 Formerly known as Chrysler Group LLC.

4 Sudbay Chrysler Dodge, Inc. 2

Deepak Gupta, of the District of Columbia (Andrew D. Nebenzahl, Carly J. LaCrosse, & Matthew W.H. Wessler also present) for the plaintiffs.

Peter M. Durney (Christopher J. Hurst also present) for FCA US LLC. The following submitted briefs for amici curiae: Ben Robbins & Daniel B. Winslow for New England Legal Foundation. Jeffrey R. White & Robert S. Peck, of the District of Columbia, Peter J. Ainsworth, Thomas R. Murphy, Kevin J. Powers, & Kyle A. Camilleri for Massachusetts Academy of Trial Attorneys & another. Cassandra Burke Robertson, Charles W. Rhodes, & Linda Sandstrom Simard, pro se. Larry E. Coben, of Pennsylvania, Michael Brooks, of the District of Columbia, & Michael K. Gillis for Center for Auto Safety & another.

KAFKER, J. Paul Doucet was rendered incapacitated by an

automobile accident in New Hampshire in 2015. His guardians

(the plaintiffs) have brought a tort suit against the

manufacturer of the car in which he was a passenger, FCA US LLC

(FCA US), and the Massachusetts distributor-dealership, Sudbay

Chrysler Dodge, Inc. (Sudbay).5 The car in question, a 2004

Chrysler Sebring, was first sold by Sudbay in Massachusetts and

later purchased in New Hampshire by Doucet, a New Hampshire

resident. At issue is whether Massachusetts has personal

jurisdiction over one of the defendants, FCA US, under the

Commonwealth's long-arm statute, G. L. c. 223A, § 3, and the due

5 Sudbay, which is incorporated in and maintains a principal place of business in Massachusetts, is not involved in this appeal. 3

process clause of the Fourteenth Amendment to the United States

Constitution. We conclude that it does, and we vacate the trial

court's dismissal of FCA US as a party to this case.6

1. Background. At this stage of the proceedings, we

"accept[] the allegations in the complaint as true and draw[]

all reasonable inferences in the plaintiff's favor." Harrington

v. Costello, 467 Mass. 720, 724 (2014). FCA US is a Delaware

limited liability company with its principal place of business

in Michigan. FCA US's predecessor in interest7 manufactured the

Sebring around which this case revolves.

A dealership in Rhode Island first received the Sebring

from the manufacturer before transferring it to Sudbay, a

dealership in Gloucester. Sudbay initially leased the car to a

Massachusetts resident in 2003. The car was then purchased by a

Massachusetts resident in 2006, and it subsequently was sold to

two other Massachusetts residents, before a New Hampshire

resident purchased the vehicle in 2011. This resident then sold

6 We acknowledge the amicus briefs submitted by New England Legal Foundation; Massachusetts Academy of Trial Attorneys and American Association for Justice; civil procedure and Federal courts professors; and Center for Auto Safety and Attorneys Information Exchange Group.

7 FCA US is the successor in interest to Chrysler Group LLC and inherited certain of its liabilities, including the products liability claim at issue. Previously, FCA US argued that it did not acquire liability for the claims brought by the plaintiffs, but it has since abandoned that argument. 4

it in a private sale to Doucet, also a New Hampshire resident,

in 2013.

In 2015, Doucet was riding in the front passenger's seat of

the Sebring when it was involved in a front-end collision in New

Hampshire. He suffered a traumatic brain injury after the

passenger's side A-pillar (windshield and roof support) struck

his head. Consequently, the plaintiffs first brought a products

liability action solely against FCA US in the Superior Court in

New Hampshire. FCA US removed the case to the United States

District Court for the District of New Hampshire, where a judge

ruled in FCA US's favor that New Hampshire lacked personal

jurisdiction over it, and dismissed the case.

The plaintiffs then filed their suit in the Superior Court

in Suffolk County against both FCA US and Sudbay (collectively,

the defendants). Again, FCA US removed the case to the Federal

District Court in the State in which the plaintiffs had filed

suit -- this time, the United States District Court for the

District of Massachusetts. The Federal District Court judge

ruled that Massachusetts has personal jurisdiction over FCA US

but remanded the matter to the Superior Court for lack of

subject matter diversity jurisdiction in the Federal court, as

the inclusion of the defendant Sudbay as a Massachusetts

corporation prevented complete diversity. 5

FCA US then filed a motion to dismiss for want of personal

jurisdiction and improper venue in the Superior Court in Suffolk

County. The motion judge transferred the case to the Superior

Court in Essex County, the county in which Sudbay operates its

sole place of business. There, after a hearing on the motion,

the judge ultimately concluded that Massachusetts lacked

personal jurisdiction over FCA US under both the Commonwealth's

long-arm statute, G. L. c. 223A, § 3, and the Federal

Constitution's due process clause.8 The judge dismissed FCA US

as a party to the case, and the plaintiffs appealed.9 We

transferred the case sua sponte from the Appeals Court.

2. Discussion. "Jurisdictional questions are questions of

law, which we review de novo." Bask, Inc. v. Municipal Council

of Taunton, 490 Mass. 312, 316 (2022). "For a nonresident to be

subject to the authority of a Massachusetts court, the exercise

of jurisdiction must satisfy both Massachusetts's long-arm

statute, G. L. c. 223A, § 3, and the requirements of the due

8 In evaluating personal jurisdiction pursuant to Federal due process, the judge in the Superior Court in Essex County found that the plaintiffs failed to establish "relatedness"; therefore, the judge did not consider other components of this analysis.

9 The plaintiffs first filed a motion for reconsideration or, in the alternative, entry of separate and final judgment on two counts of their complaint against FCA US. The trial court denied the former and allowed the latter, paving the way for this appeal. 6

process clause of the Fourteenth Amendment . . . ." Exxon Mobil

Corp. v. Attorney Gen., 479 Mass. 312, 314 (2018), cert. denied,

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