Putnam v. EPR Properties

CourtCourt of Appeals for the First Circuit
DecidedApril 28, 2026
Docket25-1857
StatusPublished

This text of Putnam v. EPR Properties (Putnam v. EPR Properties) is published on Counsel Stack Legal Research, covering Court of Appeals for the First Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Putnam v. EPR Properties, (1st Cir. 2026).

Opinion

United States Court of Appeals For the First Circuit No. 25-1857

ELIZABETH PUTNAM; CALE PUTNAM,

Plaintiffs, Appellants,

v.

EPR PROPERTIES; PREMIER PARKS, LLC,

Defendants, Appellees.

APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS

[Hon. Margaret R. Guzman, U.S. District Judge]

Before

Aframe, Howard, and Dunlap, Circuit Judges.

Benjamin R. Zimmermann, with whom Stacey L. Pietrowicz, Sarah Yun, and Sugarman & Sugarman, P.C., were on brief, for appellants.

Peter L. Bosse, with whom Karli J. Grant and Boyle Shaughnessy Law P.C. were on brief, for appellee EPR Properties.

William J. Brennan, with whom Kennedys CMK LLP was on brief, for appellee Premier Parks, LLC.

April 28, 2026 DUNLAP, Circuit Judge. Plaintiffs-Appellants Elizabeth

and Cale Putnam ("Plaintiffs") are bereaved parents whose

five-year old son, Anthony, died after an unsecured Murphy bed

fell on him in their room at the Hotel Valcartier in Québec,

Canada, where the family was vacationing. Seeking redress for the

alleged wrongful death of their son, Plaintiffs sued

Defendants-Appellees Premier Parks, LLC ("Premier") and EPR

Properties ("EPR") (together, "Defendants"), who they

believed -- based on public information -- operated and owned the

Hotel Valcartier, respectively. Premier and EPR each moved to

dismiss Plaintiffs' suit for lack of personal jurisdiction, based

on sworn statements denying that Premier or EPR owned, operated,

advertised, or booked rooms for the Hotel Valcartier. Despite

Plaintiffs' submission of documents linking Defendants to the

ownership and management of the Hotel Valcartier, the district

court dismissed Plaintiffs' complaint with prejudice and denied

Plaintiffs any jurisdictional discovery. Following our review of

the record on appeal, we affirm in part and reverse in part.

I.

At all relevant times, Plaintiffs were citizens of

Massachusetts. Premier is a limited liability company that

operates amusement and water parks in several states, not including

Massachusetts. Incorporated in Delaware, Premier has its

- 2 - headquarters in Oklahoma. EPR is a real estate investment trust

incorporated in Maryland and headquartered in Missouri.

From 2022 to 2024, Elizabeth Putnam saw advertisements

and content related to the Ice Hotel on the Hotel Valcartier

property in Québec, Canada. Sometime in late 2022 or early 2023,

she received an issue of Yankee Magazine -- a publication

targeting New England audiences -- that included an article

featuring the Ice Hotel. In October 2022, she sent an email to

info@valcartier.com inquiring about when and how she could book a

room at the Ice Hotel. In April 2023, she booked a room at the

Ice Hotel for January 14, 2024, via valcartier.com. The booking

also included a room at the Hotel Valcartier on the same night so

Plaintiffs could shower and store their luggage. The hotel

emailed Elizabeth Putnam a receipt that included her Massachusetts

mailing address. Thereafter, Elizabeth began receiving regular

marketing emails from the hotel. She also revised her hotel

reservation via email to add an extra night, received direct

marketing emails throughout the year, and later booked an activity

at the hotel's spa and added yet another night to her family's

reservation. The hotel again billed her using her Massachusetts

address. The marketing communications, emails, receipts, and

invoices that Elizabeth received listed "Village Vacances

Valcartier" as the sender. On January 12, 2024, Plaintiffs

arrived at the hotel with their son, where they noticed multiple

- 3 - Massachusetts vehicles in the hotel parking lot. Shortly after the

family arrived at the hotel, an unsecured Murphy bed fell on

Anthony and caused catastrophic head injuries that led to his death

later that night.

In October 2024, Plaintiffs brought a wrongful death

suit against Premier and EPR -- who they alleged were the operator

and owner of the Hotel Valcartier, respectively -- in the federal

district court for the District of Massachusetts, invoking

diversity jurisdiction. Plaintiffs alleged that Premier operated

the Hotel Valcartier, that EPR gave Premier possession and control

of the hotel property through a triple-net lease, and that Premier

and EPR knew or should have known that the Murphy bed that killed

Anthony had inadequate mechanisms for preventing its accidental

rapid descent to the floor. They further alleged that Premier and

EPR "regularly, continuously, and systematically market . . . the

Hotel Valcartier . . . to residents of Massachusetts," and

"solicit business from" and "contract with Massachusetts

residents." In particular, they alleged that their "cause of

action ar[ose] from [Premier and EPR's] transaction of business in

Massachusetts, namely their marketing to and contracting with the

plaintiffs in Massachusetts for the rental of rooms at Hotel

Valcartier, and the provision of [related] services." Each

defendant moved to dismiss the suit for lack of personal

jurisdiction.

- 4 - With its motion, EPR submitted an affidavit from its

director of asset management, Bob Stanion, who asserted that "EPR

does not own the Hotel Valcartier," but "has direct and indirect

ownership interests in various subsidiary entities" that "own

various properties in the United States and Canada." He further

stated that one of those subsidiaries, Valcartier Property LP,

owned "[t]he property on which the Hotel Valcartier sits" and

"entered into a triple-net lease agreement dated June 10,

2022" -- to which EPR "is not a party" -- "with Village Vacances

Valcartier Inc." Under this lease agreement, Stanion stated,

"Valcartier Property LP has no involvement in the operation,

maintenance, or business activities of the Hotel Valcartier" and

only "own[s] the property and collect[s] fixed rent from its

tenant." He averred that "[n]either EPR nor its

subsidiaries . . . direct, coordinate, control, or otherwise have

any involvement in any marketing or advertising of the Hotel

Valcartier in the Commonwealth of Massachusetts or anywhere else,"

"solicit business directly from consumers such as the Plaintiffs,"

"have any direct communications with consumers regarding the Hotel

Valcartier," or operate or maintain the hotel's website or social

media accounts.1

1 Plaintiffs have not attempted to add Valcartier Property LP as a defendant in this suit.

- 5 - In support of its motion to dismiss, Premier submitted

a declaration by its Chief Financial Officer, Jessica Cerbo.

Cerbo declared that Premier does not advertise in Massachusetts,

nor market to or contract with Massachusetts residents, including

for services or rooms at the Hotel Valcartier. She further

declared that "Premier Parks is not involved in travel bookings"

and "did not solicit, market or transact any business in

Massachusetts and/or with the Plaintiffs," but she did not

expressly state that Premier did not operate the hotel.

Plaintiffs opposed both motions to dismiss. In support,

they submitted an affidavit from Elizabeth Putnam explaining her

above-described contacts with the Hotel Valcartier. Accompanying

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Putnam v. EPR Properties, Counsel Stack Legal Research, https://law.counselstack.com/opinion/putnam-v-epr-properties-ca1-2026.