Houlihan Trading Company v. CTI Foods, LLC

CourtDistrict Court, E.D. Missouri
DecidedDecember 3, 2021
Docket4:21-cv-01030
StatusUnknown

This text of Houlihan Trading Company v. CTI Foods, LLC (Houlihan Trading Company v. CTI Foods, LLC) is published on Counsel Stack Legal Research, covering District Court, E.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Houlihan Trading Company v. CTI Foods, LLC, (E.D. Mo. 2021).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

HOULIHAN TRADING COMPANY, ) ) Plaintiff(s), ) ) v. ) Case No. 4:21-cv-01030-SRC ) CTI FOODS, LLC, ) ) Defendant(s). )

Memorandum and Order

Over the course of 20 years, Texas-based CTI Foods has done millions of dollars of business with Missouri-based Houlihan. Over that time, CTI has paid over $40 million into Houlihan’s Missouri bank account for more than 25 million pounds of poultry products. Asking the Court to cast aside these facts, CTI moves to dismiss this case for lack of personal jurisdiction, or if not, to transfer the case to CTI’s home court in Texas. The facts demonstrate that the Court has personal jurisdiction over CTI and no legitimate basis exists to transfer the case. I. Background For purposes of the Motion to Dismiss, the Court accepts as true the following facts Houlihan alleges in its complaint and includes in the affidavit accompanying its memorandum opposing CTI’s Motion to Dismiss. See Creative Calling Sols., Inc. v. LF Beauty Ltd., 799 F.3d 975, 979 (8th Cir. 2015). Houlihan, headquartered in St. Louis County, specializes in buying and selling poultry products. Doc. 1-2 at ¶ 7. CTI, headquartered in Texas, makes and sells food items containing poultry, among other things. Id. at ¶ 8. For two decades, the parties maintained a business relationship, where Houlihan supplied CTI with various poultry products. Doc. 23-1 at p. 1. According to Houlihan, the parties’ standard business practice involved CTI inquiring whether Houlihan could supply a quantity of a particular product at a certain price. Doc. 1-2 at ¶ 9. If Houlihan answered in the affirmative, CTI sent a purchase order, which Houlihan says signaled that CTI was ordering the product. Doc. 23-1 at p. 1; Doc. 1-2 at ¶ 9. Houlihan then

confirmed it was able to fill the order, and “worked with its suppliers to deliver the product.” Doc. 23-1 at p. 2. Once CTI received the delivery, it paid Houlihan, typically by wiring money into Houlihan’s Missouri bank account. Doc. 23-1 at p. 3. Toward the end of 2020, the parties communicated back and forth about prices and quantities of poultry products for the next year. Doc. 1-2 at pp. 4–5. The parties disagree about the existence of a contract for an overall amount of poultry product in 2021. The parties agree, however, that partway through 2021, Houlihan was unable to provide more frozen chicken-breast trim meat to CTI. Doc. 1-2 at p. 6; Doc. 23 at pp. 3–4; Doc. 23-5 at p. 1. CTI sent Houlihan a letter in July 2021, claiming Houlihan had breached a contract and threatening litigation if Houlihan did not provide the rest of the product or cover CTI’s costs and damages. Doc. 23-5 at

pp. 1–2. Houlihan then sought declaratory judgment in state court. II. Standard Federal Rule of Civil Procedure 12(b)(2) allows a party to move to dismiss a lawsuit for lack of personal jurisdiction. A plaintiff bears the burden to “make a prima facie showing that personal jurisdiction exists, which is accomplished by pleading sufficient facts to support a reasonable inference that the defendant can be subjected to jurisdiction within the state.” Deloney v. Chase, 755 F. App’x 592, 595 (8th Cir. 2018) (quoting K–V Pharm. Co. v. J. Uriach & CIA, S.A., 648 F.3d 588, 591–92 (8th Cir. 2011)). “Although the evidentiary showing required at the prima facie stage is minimal, the showing must be tested, not by the pleadings alone, but by the affidavits and exhibits supporting or opposing the motion.” Id. (quoting K–V Pharm. Co., 648 F.3d at 591–92). At this stage, the Court views all the evidence in the light most favorable to the plaintiff and will not dismiss the case if the evidence, when viewed in this light, “is sufficient to support a conclusion that the exercise of personal jurisdiction over [the

defendant] is proper.” Creative Calling, 799 F.3d at 979. III. Discussion A. The Court finds that specific personal jurisdiction exists over CTI in Missouri. CTI argues that the Court does not have personal jurisdiction over CTI in Missouri because CTI lacks the minimum contacts with Missouri that due process requires. Doc. 19 at p. 1. In diversity cases such as this, personal jurisdiction only exists “to the extent permitted by the long-arm statute of the forum state and by the Due Process Clause.” K–V Pharm. Co., 648 F.3d at 592 (quoting Dever v. Hentzen Coatings, Inc., 380 F.3d 1070, 1073 (8th Cir. 2004)). The Missouri long-arm statute permits a court to assert personal jurisdiction based on a number of acts, including: “(1) the transaction of any business within this state” and “(2) the making of any contract within this state . . . .” Mo. Rev. Stat. § 506.500.1. The Supreme Court of Missouri has held that courts must analyze the statutory and constitutional inquiries separately. Myers v. Casino Queen, Inc., 689 F.3d 904, 909 (8th Cir. 2012) (citing Bryant v. Smith Interior Design Grp., Inc., 310 S.W.3d 227, 231 (Mo. 2010)). Because Missouri’s long- arm statute extends “to the full extent permitted by the due process clause,” a finding that a

plaintiff has failed to establish minimum contacts under the due-process prong eliminates the need for a long-arm inquiry. See K–V Pharm. Co., 648 F.3d at 592 (quoting State ex rel. Metal Serv. Ctr. of Ga., Inc. v. Gaertner, 677 S.W.2d 325, 327 (Mo. 1984)). However, “[t]he inquiries . . . are separate,” and “[w]hile the long-arm statute extends jurisdiction to the limits of the Due Process Clause, it does so only for acts within its enumerated categories.” Dairy Farmers of Am., Inc. v. Bassett & Walker Int’l, Inc., 702 F.3d 472, 475 (8th Cir. 2012). Thus, though the parties here focused on the due-process inquiry and did not address the statutory inquiry, the Court addresses both, starting with due process.

1. CTI’s contacts with Missouri satisfy due process.

Due process requires a plaintiff to establish that “sufficient ‘minimum contacts’ exist so that ‘traditional notions of fair play and substantial justice’ are not offended.” Whaley v. Esebag, 946 F.3d 447, 451 (8th Cir. 2020) (quoting Int’l Shoe Co. v. State of Washington, 326 U.S. 310, 316 (1945)). These minimum contacts with the forum state must allow the defendant to “reasonably anticipate being haled into court there.” Id. (citation omitted). Under the Due Process Clause, a court may exercise general or specific personal jurisdiction over a defendant. See, e.g., Fastpath, Inc. v. Arbela Techs. Corp., 760 F.3d 816, 820 (8th Cir. 2014). Because Houlihan argues that the Court has specific jurisdiction over CTI, Doc. 23 at p. 5 n.1, the Court only addresses specific jurisdiction. A court’s jurisdiction over specific claims arises out of a relationship between the defendant, the forum, and the litigation. Daimler AG v. Bauman, 571 U.S. 117, 133 (2014). Specific jurisdiction requires the suit to “arise out of or relate to the defendant’s contacts with the forum.” Bristol-Myers Squibb Co. v. Super. Ct. of Cal., S.F. Cty., 137 S. Ct. 1773, 1780 (2017) (internal quotations omitted); see also Ford Motor Co. v. Montana Eighth Jud. Dist. Ct., 141 S. Ct.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

International Shoe Co. v. Washington
326 U.S. 310 (Supreme Court, 1945)
Van Dusen v. Barrack
376 U.S. 612 (Supreme Court, 1964)
Burger King Corp. v. Rudzewicz
471 U.S. 462 (Supreme Court, 1985)
Wells Dairy, Inc. v. Food Movers International, Inc.
607 F.3d 515 (Eighth Circuit, 2010)
Johnson v. Arden
614 F.3d 785 (Eighth Circuit, 2010)
K-V Pharmaceutical Co. v. J. Uriach & CIA, S.A.
648 F.3d 588 (Eighth Circuit, 2011)
Bell Paper Box, Inc. v. U.S. Kids, Inc.
22 F.3d 816 (Eighth Circuit, 1994)
Dever v. Hentzen Coatings
380 F.3d 1070 (Eighth Circuit, 2004)
Mark Myers v. Casino Queen, Inc.
689 F.3d 904 (Eighth Circuit, 2012)
Bryant v. Smith Interior Design Group, Inc.
310 S.W.3d 227 (Supreme Court of Missouri, 2010)
Wilson Tool & Die, Inc. v. TBDN-Tennessee Co.
237 S.W.3d 611 (Missouri Court of Appeals, 2007)
US Durum Milling, Inc. v. Frescala Foods, Inc.
785 F. Supp. 1369 (E.D. Missouri, 1992)
State Ex Rel. Metal Service Center of Georgia, Inc. v. Gaertner
677 S.W.2d 325 (Supreme Court of Missouri, 1984)
Daimler AG v. Bauman
134 S. Ct. 746 (Supreme Court, 2014)
Walden v. Fiore
134 S. Ct. 1115 (Supreme Court, 2014)

Cite This Page — Counsel Stack

Bluebook (online)
Houlihan Trading Company v. CTI Foods, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/houlihan-trading-company-v-cti-foods-llc-moed-2021.