Holloway v. GMRI, Inc.

CourtDistrict Court, W.D. Missouri
DecidedOctober 30, 2024
Docket5:24-cv-06094
StatusUnknown

This text of Holloway v. GMRI, Inc. (Holloway v. GMRI, Inc.) is published on Counsel Stack Legal Research, covering District Court, W.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Holloway v. GMRI, Inc., (W.D. Mo. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MISSOURI WESTERN DIVISION

DENVER HOLLOWAY, ) ) Plaintiff, ) ) v. ) No. 5:24-CV-06094-DGK ) GMRI, INC., ) d/b/a Longhorn Steakhouse, ) ) and ) ) DARDEN RESTAURANTS, INC., ) ) Defendants. )

ORDER GRANTING MOTION TO DISMISS FOR LACK OF PERSONAL JURISDICTION

This lawsuit arises from Plaintiff Denver Holloway’s allegations that she was subjected to sexual harassment and retaliation in violation of the Missouri Human Rights Act (“MHRA”) while working at a LongHorn Steakhouse in Kansas City, Missouri. Defendant GMRI, Inc. (“GMRI”) operates the LongHorn Steakhouse in question. Defendant Darden Restaurants, Inc. (“Darden”) is GMRI’s corporate parent. Now before the Court is Darden’s Motion to Dismiss for Lack of Personal Jurisdiction. ECF No. 9. The motion is GRANTED because Darden is simply the foreign corporate parent of GMRI, the entity over whom the Court possesses personal jurisdiction, which is not enough to confer personal jurisdiction over Darden. Standard Personal jurisdiction over a defendant represents the power of a court to enter a valid judgment imposing an obligation or duty over that defendant. Viasystems, Inc. v. EBM Pabst St. Georgen GmbH & Co., KG, 646 F.3d 589, 592 (8th Cir. 2011) (internal quotation marks omitted). “Personal jurisdiction can be specific or general. Specific jurisdiction refers to jurisdiction over causes of action arising from or related to a defendant’s actions within the forum state, while general jurisdiction refers to the power of a state to adjudicate any cause of

action involving a particular defendant, regardless of where the cause of action arose.” Id. at 592. Plaintiff appears to be proceeding under a theory of specific jurisdiction. Suggestions in Opp’n at 3, ECF No. 11. “Specific personal jurisdiction can be exercised by a federal court in a diversity suit only if authorized by the forum state’s long-arm statute and permitted by the Due Process Clause of the Fourteenth Amendment.” Viasystems, 646 F.3d at 593. Thus, for this Court to exercise personal jurisdiction over Darden: (1) Missouri’s long-arm statute must be satisfied; and (2) Darden must have sufficient contacts with Missouri to satisfy due process concerns. See id. Although similar in nature, these are separate inquiries. Id. at 593 n.2 (citing Bryant v. Smith Interior Design Grp., 310 S.W.3d 227, 231 (Mo. 2010)).

With respect to the first requirement, Missouri’s long-arm statute authorizes personal jurisdiction over defendants who transact business or commit a tort within the state. Id. at 593 (citing Mo. Rev. Stat. Section 506.500.01). With respect to the second requirement, due process demands there be “sufficient minimum contacts between a defendant and the forum state so that jurisdiction over a defendant with such contacts may not offend traditional notions of fair play and substantial justice.” Aly v. Hanzada for Import & Export Co., 864 F.3d 844, 849 (8th Cir. 2017) (citations and internal quotation marks omitted). That is, “[a] defendant’s contacts with the forum state must be sufficient so that a non-resident defendant should reasonably anticipate being haled into court there.” Fastpath, Inc. v. Arbela Techs. Corp., 760 F.3d 816, 820-21 (8th Cir. 2014) (citing World-Wide Volkswagen v. Woodson, 444 U.S. 286, 297 (1980)). “Sufficient minimum contacts requires some act by which the defendant purposefully avails itself of the privilege of conducting activities within the forum State, thus invoking the benefits and protections of its laws.” Id. at 821 (citation and internal quotation marks omitted). In assessing a

defendant’s minimum contacts with the forum, courts in the Eighth Circuit consider five factors: (i) the nature and quality of the contacts, (ii) the quantity of the contacts, (iii) the relationship of the cause of action to the contacts, (iv) the interest of the forum state in providing a forum to its residents, and (v) the convenience to the parties. Hanzada, 864 F.3d at 849. Courts give “significant weight to the first three factors.” Id. To defeat a motion to dismiss for lack of personal jurisdiction, the plaintiff bears the burden of making a prima facie showing that the court possesses personal jurisdiction over the defendant. Kaliannan v. Liang, 2 F.4th 727, 733 (8th Cir. 2021). “The evidentiary showing required at the prima facie stage is minimal.” Bros. and Sisters in Christ, LLC v. Zazzle, Inc., 42 F.4th 948, 951 (8th Cir. 2022). The plaintiff must show facts sufficient to support a reasonable

inference that the defendant is subject to personal jurisdiction in the state. See id. In making this determination, a court considers not only the pleadings, but also affidavits and exhibits. Pederson v. Frost, 951 F.3d 977, 979 (8th Cir. 2020). The court views the facts in the light most favorable to the nonmoving party and resolves all factual conflicts in favor of the nonmoving party. Epps v. Stewart Info. Servs. Corp., 327 F.3d 642, 647 (8th Cir. 2003). Factual and Procedural Background For purposes of resolving the pending motions, the Court finds the facts to be as follows. Defendant GMRI operates the LongHorn steakhouse restaurant in Kansas City, Missouri, where Plaintiff alleges she experienced sexual harassment and retaliation. Defendant Darden is GMRI, Inc.’s corporate parent. Darden is a Florida corporation with its principal place of business in Florida. Darden is not registered to do business in Missouri and does not have a registered agent in Missouri. Darden does not manage or operate any LongHorn restaurants, and Darden did not employ Plaintiff or any other individual who work at the

LongHorn restaurant at issue. While working at this restaurant, Plaintiff signed a Darden Employee Handbook, she was given a Darden Credit Union pay card, and she signed in and was able to check her work schedule using a Darden computer application (“app”). Discussion Darden contends this Court lacks personal jurisdiction over it because it is a parent corporation with no meaningful contacts with the forum. In response, Plaintiff does not identify a specific basis for the Court’s allegedly possession personal jurisdiction over Darden (that is, whether Darden transacts business in Missouri, committed a tort in Missouri, or both); she argues Darden is acting in a more direct manner than the typical out-of-state parent with a local

subsidiary. Alternately, Plaintiff argues she should be allowed to conduct jurisdictional discovery to determine whether there is personal jurisdiction. Plaintiff’s arguments are unavailing. Personal jurisdiction over a nonresident defendant based on the activities of an in-state subsidiary is established “only if the parent so controlled and dominated the affairs of the subsidiary that the latter’s corporate existence was disregarded so as to cause the residential corporation to act as the nonresidential corporate defendant’s alter ego.” Viasystems, 646 F.3d at 596 (internal quotation omitted).

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Related

World-Wide Volkswagen Corp. v. Woodson
444 U.S. 286 (Supreme Court, 1980)
Bryant v. Smith Interior Design Group, Inc.
310 S.W.3d 227 (Supreme Court of Missouri, 2010)
Economy Folding Box Corp. v. Anchor Frozen Foods Corp.
515 F.3d 718 (Seventh Circuit, 2008)
Fastpath, Inc. v. Arbela Technologies Corp.
760 F.3d 816 (Eighth Circuit, 2014)
Hassanin Aly v. Hanzada Import & Export, etc.
864 F.3d 844 (Eighth Circuit, 2017)
Lee Michael Pederson v. Phillip Frost
951 F.3d 977 (Eighth Circuit, 2020)
Panircelvan Kaliannan v. Ee Liang
2 F.4th 727 (Eighth Circuit, 2021)
State v. McShane
560 S.W.3d 888 (Supreme Court of Missouri, 2018)
Brothers and Sisters in Christ v. Zazzle, Inc.
42 F.4th 948 (Eighth Circuit, 2022)

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Holloway v. GMRI, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/holloway-v-gmri-inc-mowd-2024.