Miglab Travaux et Services v. United States of America and International Armoring Corporation

District Court, S.D. New York·Decided July 28, 2026·No. 1:25-cv-06318·Unknown

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ---------------------------------------------------------------------- X : MIGLAB TRAVAUX ET SERVICES, : : Plaintiffs, : : 25-CV-06318 (JAV) -v- : : OPINION AND ORDER UNITED STTAES OF AMERICA, and : INTERNATIONAL ARMORING : CORPORATION, : : Defendants. : : ---------------------------------------------------------------------- X

JEANNETTE A. VARGAS, United States District Judge:

On July 31, 2025, Plaintiff Miglab Travaux et Services (“Plaintiff” or “Miglab”) initiated this action against Defendants International Armoring Corporation (“IAC”) and the United States of America (the “Government”). See ECF No. 1. In its Amended Complaint, Plaintiff alleges that a vehicle—which Plaintiff had purchased from IAC and arranged to be shipped from Texas, United States to Togo—was seized and forfeited by United States Customs and Border Protection (“CBP”). ECF No. 27 (“Am. Compl.”), ¶¶ 14-16. Plaintiff brings a breach of contract claim against IAC. Id., ¶¶ 18-20. Plaintiff also seeks to set aside the forfeiture pursuant to 18 U.S.C. § 983(e). IAC filed a motion to dismiss pursuant to Rule 12(b)(2) of the Federal Rules of Civil Procedure. ECF No. 28. The Government filed a motion to dismiss pursuant to Rules 12(b)(1) and 12(b)(6), or in the alternative, a motion for summary judgement pursuant to Rule 56. ECF No. 36. For the reasons that follow, both IAC and the Government’s motions to dismiss are GRANTED. BACKGROUND

A. Factual Background The following allegations are derived from Plaintiff’s Amended Complaint and are accepted as true for purposes of this motion. In or about April 2020, Plaintiff contracted with Defendant IAC, purchasing a 2020 Mercedes Benz Sprinter van (the “vehicle”) from IAC for approximately $250,000. Am. Compl., ¶ 12. IAC agreed to ship the vehicle from Freeport, Texas to Lome, Togo, with an estimated departure in April 2021. Id., ¶ 14. CBP agents

seized the vehicle before it left the United States. Id., ¶ 15. Although CBP claims that on or about April 15, 2021, it sent a Notice of Seizure to Savadogo Loukouman, who brokered the transaction, Plaintiff never received the notice. Id. CBP completed the forfeiture process in January 2022, and Plaintiff received notice of the forfeiture through its former counsel on April 18, 2022. Id., ¶ 16. After Plaintiff filed a protest with CBP, CBP informed Plaintiff that it was not a party entitled to

the Notice of Seizure. Id., ¶ 17. LEGAL STANDARDS A. Rule 12(b)(1) On a motion to dismiss pursuant to Rule 12(b)(1), “[a] plaintiff asserting subject matter jurisdiction has the burden of proving by a preponderance of the evidence that it exists.” Makarova v. United States, 201 F.3d 110, 113 (2d Cir. 2000). “A case is properly dismissed for lack of subject matter jurisdiction under Rule 12(b)(1) when the district court lacks the statutory or constitutional power to adjudicate it.” Id. A motion to dismiss for lack of subject matter jurisdiction “may challenge

either the legal or factual sufficiency of the plaintiff's assertion of jurisdiction, or both.” Robinson v. Gov't of Malaysia, 269 F.3d 133, 140 (2d Cir. 2001). Where the defendant challenges the legal sufficiency of a complaint’s allegations, the court must treat all factual allegations in the complaint as true and draw all reasonable inferences in favor of the complaining party. Id. “But where evidence relevant to the jurisdictional question is before the court, the district court may refer to that

evidence.” Id. (cleaned up). B. Rule 12(b)(2) On a motion to dismiss for lack of personal jurisdiction under Rule 12(b)(2), a plaintiff bears the burden of demonstrating the Court’s personal jurisdiction over the defendants. See Penguin Grp. (USA) Inc. v. Am. Buddha, 609 F.3d 30, 34-35 (2d Cir. 2010). “In order to survive a motion to dismiss for lack of personal jurisdiction, a plaintiff must make a prima facie showing that jurisdiction exists.” Thomas v.

Ashcroft, 470 F.3d 491, 495 (2d Cir. 2006). As such, a plaintiff must show “legally sufficient allegations of jurisdiction,” including “an averment of facts that, if credited, would suffice to establish jurisdiction over the defendant.” In re Magnetic Audiotape, 334 F.3d 204, 206 (2d Cir. 2003) (cleaned up). To resolve a Rule 12(b)(2) motion, a court has “considerable procedural leeway and may decide it on the basis of affidavits alone, permit discovery in aid of the motion, or conduct an evidentiary hearing.” Struna v. Leonardi, 626 F. Supp. 3d 657, 665-66 (S.D.N.Y. 2022) (cleaned up). The court should “construe[] any pleadings and affidavits in the light most favorable to the plaintiff” but “not draw

argumentative inferences in the plaintiff's favor” nor “accept as true a legal conclusion couched as a factual allegation.” Id. (citation omitted). In addition, the court may consider matters outside the pleadings. Fed. R. Civ. P. 12(b)(2); see also Bensusan Rest. Corp. v. King, 937 F. Supp. 295, 298 (S.D.N.Y. 1996), aff'd, 126 F.3d 25 (2d Cir. 1997). C. Rule 12(b)(6)

To survive a motion to dismiss pursuant to Rule 12(b)(6), “a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Kaplan v. Lebanese Canadian Bank, SAL, 999 F.3d 842, 854 (2d Cir. 2021) (quoting Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009)). “While a complaint attacked by a Rule 12(b)(6) motion to dismiss does not need detailed factual allegations, . . . [the standard] requires more than labels[,] conclusions, and a formulaic recitation of a cause of action’s elements.” Bell Atl. Corp. v. Twombly,

550 U.S. 544, 555 (2007). To resolve a 12(b)(6) motion, a court accepts as true all well-pleaded allegations and draws all reasonable inferences in favor of the plaintiff. Romanova v. Amilus Inc, 138 F.4th 104, 108 (2d Cir. 2025). “A district court may consider the facts alleged in the complaint, documents attached to the complaint as exhibits, and documents incorporated by reference in the complaint.” Revitalizing Auto Communities Env’t Response Tr. v. Nat’l Grid USA, 92 F.4th 415, 436 (2d Cir. 2024). “Moreover, even if a document is not expressly incorporated by reference, the court may still consider it if the complaint relies heavily upon its terms and effect,

rendering the document integral to the complaint.” Id. (cleaned up). DISCUSSION A. Personal Jurisdiction Over IAC Defendant IAC contends that the Court lacks personal jurisdiction over IAC, a Utah corporation with its principal place of business in Ogden, Utah, ECF No. 30 (“Burton Decl.”), ¶ 5. The Court agrees.

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