Paul Gregory Doucet, by and through his guardians Denise Sutton and Amy Doucet v. FCA US LLC, f/k/a Chrysler Group LLC

2018 DNH 201
CourtDistrict Court, D. New Hampshire
DecidedOctober 5, 2018
Docket18-cv-627-JL
StatusPublished

This text of 2018 DNH 201 (Paul Gregory Doucet, by and through his guardians Denise Sutton and Amy Doucet v. FCA US LLC, f/k/a Chrysler Group LLC) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Paul Gregory Doucet, by and through his guardians Denise Sutton and Amy Doucet v. FCA US LLC, f/k/a Chrysler Group LLC, 2018 DNH 201 (D.N.H. 2018).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF NEW HAMPSHIRE

Paul Gregory Doucet, by and through his guardians Denise Sutton and Amy Doucet

v. Civil No. 18-cv-627-JL Opinion No. 2018 DNH 201 FCA US LLC, f/k/a Chrysler Group LLC

MEMORANDUM ORDER

The defendant’s motion to dismiss this products-liability

action turns on whether the plaintiff’s claim arises out of or

is related to the defendant’s activities in New Hampshire so as

to confer personal jurisdiction over the defendant on this

court. Plaintiff Paul Gregory Doucet brought this action in

Hillsborough Superior Court through his guardians, Denise Sutton

and Amy Doucet, alleging that he sustained injuries in a car

accident that occurred while he was a passenger in a 2004

Chrysler Sebring convertible. Defendant Fiat Chrysler

Automobiles US LLC (FCA) timely removed the action, see 28

U.S.C. § 1441, citing this court’s diversity jurisdiction, id.

§ 1332(a).

FCA moves to dismiss Doucet’s complaint, arguing that this

court lacks personal jurisdiction over it. See Fed. R. Civ.

P. 12(b)(2). After holding oral argument, the court grants that motion.1 Doucet’s claim arises from alleged defects in the 2004

Sebring, which FCA’s predecessor, Chrysler, LLC, originally sold

in Massachusetts. Though Chrysler, LLC, and subsequently FCA,

may have sold other vehicles--including other 2004 Sebrings--in

New Hampshire, Doucet has not carried his burden of

demonstrating that his claims are causally related to those

activities. The court therefore lacks personal jurisdiction

over FCA.

Applicable legal standard

“Personal jurisdiction implicates the power of a court over

a defendant . . . . [B]oth its source and its outer limits are

defined exclusively by the Constitution.” Foster–Miller, Inc.

v. Babcock & Wilcox Can., 46 F.3d 138, 143–44 (1st Cir. 1995)

(citing Ins. Corp. of Ir., Ltd. v. Compagnie des Bauxites de

Guinee, 456 U.S. 694, 702 (1982)); U.S. Const. amend. V. “To

establish personal jurisdiction in a diversity case, a plaintiff

must satisfy both the forum state’s long-arm statute and the Due

Process Clause of the Fourteenth Amendment.” C.W. Downer & Co.

v. Bioriginal Food & Sci. Corp., 771 F.3d 59, 65 (1st Cir.

2014). “New Hampshire’s long-arm statute reaches to the full

1 FCA also moves to dismiss Doucet’s negligence claim against it. See Fed. R. Civ. P. 12(b)(6). Because the court concludes that it lacks personal jurisdiction over FCA, it need not--and therefore does not--address the merits of that claim.

2 extent that the Constitution allows.” Phillips Exeter Acad. v.

Howard Phillips Fund, 196 F.3d 284, 287 (1st Cir. 1999). The

court thus proceeds directly to the usual constitutional due

process analysis.

To satisfy the requirements of due process, the defendants

must have sufficient “minimum contacts” with the forum “such

that the maintenance of the suit does not offend traditional

notions of fair play and substantial justice.” Int’l Shoe Co.

v. Washington, 326 U.S. 310, 316 (1945) (internal quotations

omitted). Consistent with these threshold requirements, “[a]

district court may exercise authority over a defendant by virtue

of either general or specific jurisdiction.” Mass. Sch. Of Law

at Andover, Inc. v. Am. Bar Ass’n., 142 F.3d 26, 34 (1st Cir.

1998).

The plaintiff invokes only this court’s specific

jurisdiction over the defendant.2 “[S]pecific jurisdiction is

confined to adjudication of issues deriving from, or connected

with, the very controversy that establishes jurisdiction.”

Goodyear, 564 U.S. at 919 (internal quotations omitted). “[T]he

2 As FCA demonstrated in its opening memorandum, see Mem. in Supp. of Mot. to Dismiss (doc. no. 4) at 8-9, the requirements for general jurisdiction over it are not satisfied here. See Daimler AG v. Bauman, 571 U.S. 117, 136 (2014). Doucet does not dispute this, nor allege general jurisdiction in this action. Cf. Plaintiff’s Obj. (doc. no. 7) at 5 & n. 6.

3 constitutional test for determining specific jurisdiction . . .

has three distinct components, namely, relatedness, purposeful

availment (sometimes called ‘minimum contacts’), and

reasonableness.” Adelson v. Hananel, 652 F.3d 75, 80–81 (1st

Cir. 2011) (internal quotations and citations omitted).

“[D]ivining personal jurisdiction is ‘more an art than a

science,’” Sawtelle v. Farrell, 70 F.3d 1381, 1388 (1st Cir.

1995) (quoting Ticketmaster-N.Y., Inc. v. Alioto, 26 F.3d 201,

206 (1st Cir. 1994)), and thus necessitates “an individualized

assessment and factual analysis of the precise mix of contacts

that characterize each case,” Pritzker v. Yari, 42 F.3d 53, 60

(1st Cir. 1994).

Doucet bears the burden of satisfying these three

components by “proffer[ing] evidence which, if credited, is

sufficient to support findings of all facts essential to

personal jurisdiction.” A Corp. v. All Am. Plumbing, Inc., 812

F.3d 54, 58 (1st Cir. 2016) (quoting Phillips v. Prairie Eye

Ctr., 530 F.3d 22, 26 (1st Cir. 2008)). “To satisfy the prima

facie standard in a specific jurisdiction case, a plaintiff may

not rest on mere allegations but, rather, must submit competent

evidence showing sufficient dispute-related contacts between the

defendant and the forum.”3 Carreras v. PMG Collins, LLC, 660

3 The First Circuit Court of Appeals recognizes three methods of determining whether personal jurisdiction exists over the

4 F.3d 549, 552 (1st Cir. 2011). The court “view[s] this

evidence, together with any evidence proffered by the

defendant[s], in the light most favorable to the plaintiff and

draw[s] all reasonable inferences therefrom in the plaintiff’s

favor,” albeit without “credit[ing] bald allegations or

unsupported conclusions.” Id. This approach informs the

following factual summary.

Background

Doucet was sitting in the front passenger seat of a 2004

Chrysler Sebring when it collided with another vehicle in

Hudson, New Hampshire, on May 24, 2015. A vertical support beam

on the passenger side deflected inwards, injuring Doucet.

The 2004 Sebring was designed and manufactured by Chrysler,

LLC, which sold it to a dealer in Rhode Island.4 That dealer

transferred it to another in Gloucester, Massachusetts, which

defendant: the prima facie method, the preponderance method, and the likelihood method. A Corp. v.

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International Shoe Co. v. Washington
326 U.S. 310 (Supreme Court, 1945)
Foster-Miller, Inc. v. Babcock & Wilcox Canada
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Alers-Rodriguez v. National Insurance
115 F.3d 81 (First Circuit, 1997)
United States v. Swiss American Bank, Ltd.
274 F.3d 610 (First Circuit, 2001)
Phillips v. Prairie Eye Center
530 F.3d 22 (First Circuit, 2008)
Adelson v. Hananel
652 F.3d 75 (First Circuit, 2011)
Ticketmaster-New York, Inc. v. Joseph M. Alioto
26 F.3d 201 (First Circuit, 1994)
Jay A. Pritzker v. Bob Yari
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Arthur F. Sawtelle, Etc. v. George E. Farrell
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