Foundation for Anime and Niche Subcultures v. Texas Anime Conventions

CourtDistrict Court, N.D. California
DecidedMarch 4, 2025
Docket5:24-cv-07120
StatusUnknown

This text of Foundation for Anime and Niche Subcultures v. Texas Anime Conventions (Foundation for Anime and Niche Subcultures v. Texas Anime Conventions) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Foundation for Anime and Niche Subcultures v. Texas Anime Conventions, (N.D. Cal. 2025).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 FOUNDATION FOR ANIME AND NICHE Case No. 5:24-cv-07120-PCP SUBCULTURES, 8 Plaintiff, ORDER GRANTING MOTIONS TO 9 DISMISS v. 10 Re: Dkt. Nos. 42, 44 TEXAS ANIME CONVENTIONS, et al., 11 Defendants.

12 In this lawsuit, Foundation for Anime and Niche Subcultures (FANS) brings claims for 13 conversion and unjust enrichment against defendants Texas Anime Convention (TAC), Melissa 14 Henderson, and Corrine Howlett. The claims arise from the alleged misappropriation of FANS’s 15 funds and their diversion to TAC. Defendants now move to dismiss FANS’s claims for lack of 16 personal jurisdiction.1 For the following reasons, the Court grants the motions to dismiss. 17 BACKGROUND 18 FANS is a California nonprofit public benefit corporation whose principal business is to 19 promote appreciation of Asian culture, media, and underrepresented subcultures. TAC is a Texas 20 nonprofit whose principal business is running conventions. Henderson is the founder and director 21 of TAC and a resident of Texas. Corrine Howlett is the former CEO of TAC and a resident of 22 Virginia. Craige Howlett, who is not a party to this lawsuit, previously served as the volunteer 23 Chief Financial Officer of FANS. Corrine Howlett and Craige Howlett were previously married.2 24 In August 2022, FANS discovered that Craige Howlett had been misappropriating funds 25 26 1 Pro se defendant Corrine Howlett filed her motion as a motion for declaratory judgment. Based 27 on its substantive arguments, the Court will construe it as a motion to dismiss. 1 from FANS. FANS believes that Craige Howlett misappropriated more than $656,000 between 2 September 2020 and August 2022. During that period, Craige Howlett also served as a corporate 3 representative of TAC, in which role he managed TAC’s finances. FANS alleges that Craige 4 Howlett diverted some of the misappropriated FANS funds to TAC. Corrine Howlett also served 5 as a corporate representative of TAC at that time. She was allegedly aware that her then-husband 6 was misappropriating funds from FANS and that some of those funds were diverted to TAC, and 7 she allegedly used misappropriated FANS funds for her own personal benefit. Additionally, FANS 8 alleges that TAC used some of the funds misappropriated from FANS to finance an unrelated 9 defamation lawsuit brought by Henderson and TAC against several other parties. 10 FANS brings claims against TAC, Henderson, and Corrine Howlett for conversion and 11 unjust enrichment. Defendants now move to dismiss pursuant to Federal Rule of Civil Procedure 12 12(b)(2).3 13 LEGAL STANDARDS 14 Federal Rule 4(k)(1)(A) provides that, in the absence of a federal statute governing 15 personal jurisdiction, “the district court applies the law of the state in which the district court sits.” 16 Schwarzenegger v. Fred Martin Motor Co., 374 F.3d 797, 800 (9th Cir. 2004). Since “California’s 17 long-arm jurisdictional statute is coextensive with federal due process requirements, the 18 jurisdictional analyses under state law and federal due process are the same.” Id. at 800–01. 19 In order for a court to exercise personal jurisdiction over a particular defendant, due 20 process requires that the defendant have “minimum contacts” with the chosen forum such that the 21 exercise of jurisdiction “does not offend traditional notions of fair play and substantial justice.” 22 23 3 FANS asserts that the Court should not consider Corrine Howlett’s motion to dismiss because it 24 is untimely. Under Federal Rule of Civil Procedure 12(b), “[e]very defense to a claim for relief in any pleading must be asserted in the responsive pleading if one is required.” Corrine Howlett filed 25 answers to FANS’s first amended complaint on December 30, 2024 and January 2, 2025. See Dkt. Nos. 34 & 36. Consequently, FANS contends, Corrine Howlett waived her right to subsequently 26 move to dismiss. Both of the “answers” that Corrine Howett filed, however, were letters to the Court primarily concerned with the challenges of defending this litigation pro se. Given the 27 Court’s duty to construe pro se filings liberally, see Zichko v. Idaho, 247 F.3d 1015, 1020 (9th Cir. 2001) (as amended) (June 5, 2001), the Court will construe Corrine Howlett’s “answers” as letters 1 Int’l Shoe Co. v. Washington, 326 U.S. 310, 316 (1945) (cleaned up). The “minimum contacts” 2 required by due process depend on whether a court is exercising general or specific jurisdiction. 3 General jurisdiction extends to all claims that might be asserted against a defendant and 4 thus requires a substantial degree of contact with the forum. “For an individual, the paradigm 5 forum for the exercise of general jurisdiction is the individual’s domicile.” Goodyear Dunlop 6 Tires Operations, S.A. v. Brown, 564 U.S. 915, 924 (2011). “A court may assert general 7 jurisdiction over foreign … corporations to hear any and all claims against them when their 8 affiliations with the State are so ‘continuous and systematic’ as to render them essentially at home 9 in the forum State.” Id. at 919. For corporations, the “paradigm” bases for general jurisdiction are 10 “the place of incorporation and principal place of business,” although operations in another state 11 might also be “so substantial and of such a nature as to render the corporation at home in that 12 State.” Daimler AG v. Bauman, 571 U.S. 117, 137, 139 n.19 (2014). 13 Specific jurisdiction “covers defendants less intimately connected with a State, but only as 14 to a narrower class of claims.” Ford Motor Co. v. Mont. Eighth Jud. Dist. Ct., 592 U.S. 351, 352 15 (2021). District courts in California apply a three-part test to determine whether they can exercise 16 specific personal jurisdiction over a defendant: (1) the non-resident defendant must purposefully 17 direct its activities or consummate some transaction with the forum or resident thereof, or perform 18 some act by which it purposefully avails itself of the privilege of conducting activities in the 19 forum, thereby invoking the benefits and protections of its laws; (2) the claim must be one which 20 arises out of or relates to the defendant’s forum-related activities; and (3) the exercise of 21 jurisdiction must comport with fair play and substantial justice. See, e.g., Core-Vent Corp. v. 22 Nobel Indus., AB, 11 F.3d 1482, 1485 (9th Cir. 1993). 23 For purposes of the test’s first part, “availment and direction are, in fact, two distinct 24 concepts.” Schwarzenegger, 374 F.3d at 802. A showing of purposeful availment “typically 25 consists of evidence of the defendant’s actions in the forum,” whereas a showing of purposeful 26 direction “usually consists of evidence of the defendant’s actions outside the forum state that are 27 directed at the forum state.” Schwarzenegger, 374 F.3d at 802–803. Whether a court applies the 1 Generally, courts apply the purposeful direction test for tort claims and the purposeful availment 2 test for claims sounding in contract. Nichols v. Guidetoinsure, LLC, No. 23-CV-04920-PCP, 2024 3 WL 1643701, at *2 (N.D. Cal. Apr. 15, 2024); Boschetto v. Hansing, 539 F.3d 1011

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Bluebook (online)
Foundation for Anime and Niche Subcultures v. Texas Anime Conventions, Counsel Stack Legal Research, https://law.counselstack.com/opinion/foundation-for-anime-and-niche-subcultures-v-texas-anime-conventions-cand-2025.