MURPHY v. TITLEMAX OF VIRGINIA, INC.

CourtDistrict Court, M.D. North Carolina
DecidedMay 29, 2025
Docket1:22-cv-00971
StatusUnknown

This text of MURPHY v. TITLEMAX OF VIRGINIA, INC. (MURPHY v. TITLEMAX OF VIRGINIA, INC.) is published on Counsel Stack Legal Research, covering District Court, M.D. North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
MURPHY v. TITLEMAX OF VIRGINIA, INC., (M.D.N.C. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF NORTH CAROLINA

) ADRIAN MURPHY, et al., ) ) Plaintiffs, ) ) 1:22CV971 v. ) ) TITLEMAX OF VIRGINIA, et al., ) ) Defendants. ) )

MEMORANDUM OPINION AND ORDER LORETTA C. BIGGS, District Judge. Adrian Murphy, et al. (“Plaintiffs”)1 brought this action pursuant to the North Carolina Consumer Finance Act, the North Carolina Unfair and Deceptive Trade Practices Act, and North Carolina’s usury statutes against TitleMax of Virginia, Inc., TitleMax of South Carolina, Inc., TMX Finance of Virginia, Inc., and TitleMax of Georgia, Inc. (“Defendants”). (See ECF No. 2 ¶¶ 22, 28, 41.) Before the Court is Defendants’ Motion to Dismiss for Lack of Personal Jurisdiction, or, in the Alternative, to Transfer Venue. (ECF No. 36.) For the reasons stated herein, Defendants’ motion will be denied. I. BACKGROUND Plaintiffs in this action are, or were, residents of North Carolina who allegedly entered into car title loan transactions with Defendants. (ECF No. 2 ¶ 1.) Plaintiffs allege that Defendants charged interest rates on their car title loans that exceed the rate allowed by the North Carolina Consumer Finance Act, N.C. GEN. STAT. §§ 24-1.1, 53-164 to -191. (Id. ¶¶

1While Plaintiffs in this action exceeds several hundred individuals as outlined in the Complaint, (ECF 22, 28.) Plaintiffs also allege that Defendants failure to disclose that the loan was unlawful constitutes unfair and deceptive trade practices within the meaning of N.C. GEN. STAT. § 53- 180(g) and N.C. GEN. STAT. § 75-1.1. (Id. ¶ 41.) This action began in state court and Defendants removed it to federal court on the basis of diversity jurisdiction. (ECF No. 1 at 4.) On November 14, 2022, Plaintiffs filed their

Complaint with this Court. (See ECF No. 2.) In their Complaint, Plaintiffs state that this Court has personal jurisdiction over Defendants “in that at all times relevant to the events and transactions alleged herein, Defendants, via the internet, cellular telephone and/or other media and communication methods solicited, marketed, advertised, offered, accepted, discussed, negotiated, facilitated, collected on, threatened enforcement of, and/or foreclosed upon automobile title loans with Plaintiffs.” (Id. ¶ 4.)

In Defendants’ answer, they assert a lack of personal jurisdiction as a defense, and subsequently Defendants jointly filed the instant Motion to Dismiss alleging lack of personal jurisdiction. (ECF Nos. 6 at 6; 36 at 1.) On October 5, 2023, Plaintiffs filed a Motion for Jurisdictional Discovery to “provide a full record [in] response to Defendants’ Motion to Dismiss.” (ECF No. 48 at 1.) This motion was granted in part, and the parties conducted jurisdictional discovery. (ECF No. 57 at 2–3.)

In the instant motion to dismiss, Defendants argue that this Court lacks personal jurisdiction because Defendants do not “maintain contacts with North Carolina in connection with any [of] Plaintiffs’ claims.” (ECF No. 37 at 3.) Defendants alternatively argue for this Court to transfer venue to the district court where each of the designated Plaintiffs’ “title loan was executed[,] and the loan funds were conveyed.” (Id. at 17.) The Court will address each

argument in turn. II. MOTION TO DISMISS FOR LACK OF PERSONAL JURISDICTION A. Standard of Review Here, the parties are in dispute regarding the burden of proof Plaintiffs must satisfy to show that this Court has personal jurisdiction over Defendants. Defendants argue that Plaintiffs must show personal jurisdiction by a preponderance of the evidence and Plaintiffs counter that they need only make a prima facie showing. (ECF Nos. 57 at 1; 63 at 7; 69 at 1.)

In a challenge to personal jurisdiction under Rule 12(b)(2) of the Federal Rules of Civil Procedure, the plaintiff bears the ultimate burden of proving jurisdiction. Grayson v. Anderson, 816 F.3d 262, 267 (4th Cir. 2016) (citation omitted); see also Carefirst of Md., Inc. v. Carefirst Pregnancy Ctrs., Inc., 334 F.3d 390, 396 (4th Cir. 2003) (citation omitted). The Fourth Circuit has stated that the plaintiff's burden of proof “varies according to the posture of [the] case and the evidence that has been presented to the court.” Grayson, 816 F.3d at 268.

Where the court decides a pretrial personal jurisdiction question without conducting an evidentiary hearing — “reviewing only the parties’ motion papers, affidavits attached to the motion, supporting legal memoranda, and the allegations in the complaint”— “a plaintiff need only make a prima facie showing of personal jurisdiction” to overcome a jurisdictional challenge. Id. Where, however, the parties have engaged in discovery on the issue of personal jurisdiction and have submitted evidence beyond the pleadings, the court “must hold the

plaintiff to its burden of proving facts, by a preponderance of the evidence, that demonstrate the court's personal jurisdiction over the defendant.” Id.; see also, e.g., AARP v. Am. Family Prepaid Legal Corp., 604 F.Supp.2d 785, 797 (M.D.N.C. Feb 25, 2009) (holding the plaintiff to a preponderance of the evidence standard because the parties had engaged in jurisdictional discovery). Here, this Court granted Plaintiffs’ Motion for Jurisdictional Discovery, (ECF No. 57 at 2–3), and jurisdictional discovery was conducted. As the Court will look to evidence outside of the pleadings in resolving the issue of personal jurisdiction, Plaintiffs are required to establish personal jurisdiction by a preponderance of the evidence. See Grayson, 816 F.3d at 269 (finding that the preponderance of the evidence standard was correctly applied as “full

discovery had been conducted and the relevant evidence on jurisdiction had been presented to the court”). A “preponderance of the evidence . . . simply requires the trier of fact to believe that the existence of a fact is more probable than its nonexistence.” Concrete Pipe and Prods. of California, Inc. v. Constr. Laborers Pension Tr. for S. Cal., 508 U.S. 602, 622 (1993) (internal quotation marks omitted) (citation omitted). “[I]f a court requires the plaintiff to establish

facts supporting personal jurisdiction by a preponderance of the evidence prior to trial, it must conduct an evidentiary hearing.” Grayson, 816 F.3d at 268 (internal quotations omitted). However, evidentiary hearings do not require live testimony. Id. Evidentiary hearings require that both parties are given a fair opportunity to present relevant jurisdictional evidence and their legal arguments. Id.; see also Sec. & Exch. Comm’n v. Receiver for Rex Ventures Grp., LLC., 730 F. App’x 133, 136 (4th Cir. 2018) (citation omitted).

This Court does not find an evidentiary hearing necessary in this case as the parties were permitted to conduct jurisdictional discovery that included submitting requests for productions, taking depositions, and obtaining documentation relating to the loans. (ECF No. 57 at 2–3.) Additionally, the parties have extensively briefed the issue of personal jurisdiction. (See ECF Nos. 37; 63; 69.) Thus, both sides have had a fair opportunity to present

jurisdictional evidence and their legal arguments. See Grayson, 816 F.3d at 268. As the Court has now determined that Plaintiffs must establish personal jurisdiction by a preponderance of the evidence, it will now address whether they have met their burden. B. Discussion “The Due Process Clause of the Fourteenth Amendment constrains a State’s authority to bind a nonresident defendant to a judgment of its courts.” Walden v. Fiore, 571 U.S. 277,

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

Related

World-Wide Volkswagen Corp. v. Woodson
444 U.S. 286 (Supreme Court, 1980)
Keeton v. Hustler Magazine, Inc.
465 U.S. 770 (Supreme Court, 1984)
Helicopteros Nacionales De Colombia, S. A. v. Hall
466 U.S. 408 (Supreme Court, 1984)
Burger King Corp. v. Rudzewicz
471 U.S. 462 (Supreme Court, 1985)
Goodyear Dunlop Tires Operations, S. A. v. Brown
131 S. Ct. 2846 (Supreme Court, 2011)
Consulting Engineers Corp. v. Geometric Ltd.
561 F.3d 273 (Fourth Circuit, 2009)
AARP v. American Family Prepaid Legal Corp., Inc.
604 F. Supp. 2d 785 (M.D. North Carolina, 2009)
Wyandotte Nation v. Salazar
825 F. Supp. 2d 261 (District of Columbia, 2011)
Speed Trac Technologies, Inc. v. Estes Express Lines, Inc.
567 F. Supp. 2d 799 (M.D. North Carolina, 2008)
Daimler AG v. Bauman
134 S. Ct. 746 (Supreme Court, 2014)
Walden v. Fiore
134 S. Ct. 1115 (Supreme Court, 2014)
Universal Leather, LLC v. KORO AR, S.A.
773 F.3d 553 (Fourth Circuit, 2014)
Christian Science Board of Directors v. Nolan
259 F.3d 209 (Fourth Circuit, 2001)

Cite This Page — Counsel Stack

Bluebook (online)
MURPHY v. TITLEMAX OF VIRGINIA, INC., Counsel Stack Legal Research, https://law.counselstack.com/opinion/murphy-v-titlemax-of-virginia-inc-ncmd-2025.