Eureka Resources, LLC v. Howden Roots, LLC

CourtDistrict Court, M.D. Pennsylvania
DecidedAugust 11, 2021
Docket4:20-cv-02222
StatusUnknown

This text of Eureka Resources, LLC v. Howden Roots, LLC (Eureka Resources, LLC v. Howden Roots, LLC) is published on Counsel Stack Legal Research, covering District Court, M.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Eureka Resources, LLC v. Howden Roots, LLC, (M.D. Pa. 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA

EUREKA RESOURCES, LLC, No. 4:20-CV-02222

Plaintiff, (Judge Brann)

v.

HOWDEN ROOTS LLC,

Defendant.

MEMORANDUM OPINION

AUGUST 11, 2021 I. BACKGROUND On February 5, 2021, Eureka Resources, LLC filed a two-count amended complaint against Howden Roots LLC alleging breach of contract. Howden then filed a motion to dismiss pursuant to Federal Rules of Civil Procedure 12(b)(3) and 12(b)(6). The motion is now ripe for disposition; for the reasons that follow, Howden’s motion is denied. II. STANDARD OF REVIEW Under Rule 12(b)(6), the Court dismisses a complaint, in whole or in part, if the plaintiff has failed to “state a claim upon which relief can be granted.” Under Rule 12(b)(6), a motion to dismiss “tests the legal sufficiency of a pleading”1 and

1 Richardson v. Bledsoe, 829 F.3d 273, 289 n.13 (3d Cir. 2016) (Smith, C.J.) (citing Szabo v. “streamlines litigation by dispensing with needless discovery and factfinding.”2 “Rule 12(b)(6) authorizes a court to dismiss a claim on the basis of a dispositive

issue of law.”3 This is true of any claim, “without regard to whether it is based on an outlandish legal theory or on a close but ultimately unavailing one.”4 Rule 12(b)(6) also authorizes dismissal to enforce a forum-selection clause.5 Following the Roberts Court’s “civil procedure revival,”6 the landmark

decisions of Bell Atlantic Corporation v. Twombly7 and Ashcroft v. Iqbal8 tightened the standard that district courts must apply to 12(b)(6) motions.9 These cases “retired” the lenient “no-set-of-facts test” set forth in Conley v. Gibson and

replaced it with a more exacting “plausibility” standard.10 Accordingly, after the Twombly and Iqbal decisions, “[t]o survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’”11 “A claim has facial

2 Neitzke v. Williams, 490 U.S. 319, 326–27 (1989). 3 Id. at 326 (citing Hishon v. King & Spalding, 467 U.S. 69, 73 (1984)). 4 Id. at 327. 5 Atl. Marine Constr. Co. v. U.S. Dist. Court, 571 U.S. 49, 55 (2013). A party can enforce a forum-selection clause under Rule 12(b)(6) or the doctrine of forum non conveniens when the matter is brought in a federal court and the applicable forum-selection clause points to a state forum. Id. A party cannot enforce a forum-selection clause under Rule 12(b)(3). Id. at 52. Therefore, Howden’s motion to dismiss the amended complaint pursuant to Rule 12(b)(3) is denied. 6 Howard M. Wasserman, The Roberts Court and the Civil Procedure Revival, 31 Rev. Litig. 313, 316, 319-20 (2012). 7 550 U.S. 544 (2007). 8 556 U.S. 662, 678 (2009). 9 Id. at 670. 10 Id. plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.”12

“Although the plausibility standard does not impose a probability requirement, it does require a pleading to show more than a sheer possibility that a defendant has acted unlawfully.”13 Moreover, “[a]sking for plausible grounds . . . calls for

enough facts to raise a reasonable expectation that discovery will reveal evidence of [wrongdoing].”14 When disposing of a motion to dismiss, the Court “accept[s] as true all factual allegations in the complaint and draw[s] all inferences from the facts

alleged in the light most favorable to [the plaintiff].”15 However, “the tenet that a court must accept as true all of the allegations contained in the complaint is inapplicable to legal conclusions.”16 “Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.”17

As a matter of procedure, the United States Court of Appeals for the Third Circuit has instructed that: Under the pleading regime established by Twombly and Iqbal, a court reviewing the sufficiency of a complaint must take three steps. First, it must tak[e] note of the elements [the] plaintiff must plead to state a

12 Id. 13 Connelly v. Lane Constr. Corp., 809 F.3d 780, 786 (3d Cir. 2016) (Jordan, J.) (internal quotations and citations omitted). 14 Twombly, 550 U.S. at 556. 15 Phillips v. Cnty. of Allegheny, 515 F.3d 224, 228 (3d Cir. 2008) (Nygaard, J.). 16 Iqbal, 556 U.S. at 678 (internal citations omitted); see also Fowler v. UPMC Shadyside, 578 F.3d 203, 210 (3d Cir. 2009) (Nygaard, J.) (“After Iqbal, it is clear that conclusory or ‘bare- bones’ allegations will no longer survive a motion to dismiss.”). claim. Second, it should identify allegations that, because they are no more than conclusions, are not entitled to the assumption of truth. Finally, [w]hen there are well-pleaded factual allegations, [the] court should assume their veracity and then determine whether they plausibly give rise to an entitlement to relief.18 “Generally, consideration of a motion to dismiss under Rule 12(b)(6) is limited to consideration of the complaint itself.”19 Therefore, a motion ordinarily to dismiss must be converted to a motion for summary judgment for the court to consider materials outside the complaint.20 A court may, however, consider the full text of documents that are partially quoted in the complaint21 as well as materials that the plaintiff relied upon in drafting and which are integral to the complaint.22 “[B]efore materials outside the record may become the basis for a

dismissal, several conditions must be met.”23 “For example, even if a document is ‘integral’ to the complaint, it must be clear on the record that no dispute exists regarding the authenticity or accuracy of the document.”24 It must also be clear

that no material disputed issues of fact exist regarding the relevance of the document.25

18 Connelly, 809 F.3d at 787 (internal quotations and citations omitted). 19 Faulkner v. Beer, 463 F.3d 130, 134 (2d Cir. 2006). 20 See id.; Fed. R. Civ. P. 12(d). 21 San Leandro Emergency Med. Group Profit Sharing Plan v. Philip Morris Co., 75 F.3d 801, 808-09 (2d Cir.1996). 22 Cortec Indus., Inc. v. Sum Holding L.P., 949 F.2d 42, 47-48 (2d Cir.1991). 23 Faulkner, 463 F.3d at 134. 24 Id.; see also, e.g., Kaempe v. Myers, 367 F.3d 958, 965 (D.C. Cir. 2004); Alt. Energy, Inc. v. St. Paul Fire & Marine Ins. Co., 267 F.3d 30, 33 (1st Cir. 2001). I find that the preceding conditions have been met for documents offered in this matter relating to the formation of a contract between Howden and Eureka.

This includes emails sent by Howden to Eureka in June, September, and October 2020 and purchase orders sent by Eureka to Howden in October.26 However, the Court will not consider the affidavit of Howden employee Brian Boyle because it is neither quoted in nor integral to the amended complaint.27 The Court further

does not consider the document that Howden claims is the true copy of Eureka’s June purchase order as there is a material dispute of fact regarding the authenticity of Howden’s proffered version.

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Eureka Resources, LLC v. Howden Roots, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/eureka-resources-llc-v-howden-roots-llc-pamd-2021.