State Farm and Casualty Company v. Broan-Nutone LLC

CourtDistrict Court, N.D. Alabama
DecidedMarch 31, 2022
Docket2:22-cv-00058
StatusUnknown

This text of State Farm and Casualty Company v. Broan-Nutone LLC (State Farm and Casualty Company v. Broan-Nutone LLC) is published on Counsel Stack Legal Research, covering District Court, N.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State Farm and Casualty Company v. Broan-Nutone LLC, (N.D. Ala. 2022).

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION STATE FARM FIRE and CASUALTY } COMPANY, et al., } } Plaintiffs, } } Case No.: 2:22-CV-58-RDP v. } } BROAN-NUTONE LLC, et al., } } Defendants. }

MEMORANDUM OPINION

This matter is before the court on Defendant A.O. Smith Corporation’s Motion to Dismiss (Doc. # 6). A.O. Smith seeks dismissal of Plaintiffs’ claims against it for lack of personal jurisdiction. (Id.). Plaintiffs, State Farm Fire and Casualty Co., and Vameshia Carmichael, have filed a Response to the Motion that indicates that the Motion is unopposed because Plaintiffs do not have sufficient evidence to establish personal jurisdiction over A.O. Smith. (Doc. # 17). After careful consideration, and for the reasons explained below, the court concludes A.O. Smith’s Motion is due to be granted. I. Background On or about January 18, 2020, a ventilation fan manufactured by Defendant Broan-Nutone LLC (“Broan”) and containing an A.O. Smith manufactured fan motor, self-ignited resulting in substantial damages to Carmichael’s home in Fultondale, Alabama, and personal property located in the home. (Doc. # 1 ¶ 11). State Farm reimbursed its insured, Carmichael, for the value of the damaged home and property and became subrogated to the rights of its insured under the applicable policy. (Doc. # 1 ¶¶ 13, 15). In the Complaint, Plaintiffs assert negligence, AEMLD, failure to warn, and breach of warranty clams against A.O. Smith. (Doc. # 1, generally). Plaintiffs also sued Broan-Nutone LLC, the manufacturer of the fan. (Doc. # 1 ¶ 3). A.O. Smith is a Delaware corporation with its principal place of business located in Milwaukee, Wisconsin. (Doc. # 6-1 ¶¶ 4-5). A.O. Smith has no manufacturing facilities or administrative offices in Alabama. (Id. at ¶¶ 6-7). Further, A.O. Smith did not design, develop,

manufacture, or test any electric motor component supplied for the bathroom exhaust fan at issue in this case within the State of Alabama. (Id. at ¶¶ 13-14). A.O. Smith did not participate in the final assembly or sale of the subject exhaust fan. (Id. at ¶ 16). A.O. Smith sold its motor division in 2011, more than ten years ago. (Id. at ¶ 12). All motors A.O. Smith sold to Broan for inclusion in its ventilation products were custom made for Broan and were not sold to other customers. (Doc. # 6-2 ¶ 4). A.O. Smith did not design, develop, or manufacture any of the electric motor component parts it sold to Broan in the state of Alabama. (Doc. # 6-1 ¶ 13). There is no record of any shipments of motors being made to Broan within the state of Alabama. (Id. at ¶ 15). A.O. Smith did not participate in the final assembly,

retail sale, or consumer distribution of the subject fan or any Broan products. (Id. at ¶ 16). That is, A.O. Smith is an out-of-state corporation having no continuous and systematic affiliations or contacts with Alabama. (Id., generally). In their Response to A.O. Smith’s Motion, Plaintiffs state: Plaintiffs conclude that they do not have enough facts to show Defendant has sufficient affiliations with the forum state in relation to the controversy at hand to satisfy the purposeful availment prong of the Eleventh Circuit’s due process test for specific jurisdiction, and therefore concede Defendant’s Motion is due to be granted. (Doc. # 17 at 2, ¶ 4). II. Standard of Review A Rule 12(b)(2) motion tests the court’s exercise of personal jurisdiction over a defendant. See Fed. R. Civ. P. 12(b)(2). “A plaintiff seeking the exercise of personal jurisdiction over a nonresident defendant bears the initial burden of alleging in the complaint sufficient facts to make out a prima facie case of jurisdiction.” United Techs. Corp. v. Mazer, 556 F.3d 1260, 1274 (11th

Cir. 2009); see also Posner v. Essex Ins. Co., 178 F.3d 1209, 1214 (11th Cir. 1999) (“A plaintiff seeking to obtain jurisdiction over a nonresident defendant initially need only allege sufficient facts to make out a prima facie case of jurisdiction.”). If the plaintiff satisfies his initial burden and the defendant then challenges personal jurisdiction by submitting affidavit evidence or deposition testimony, the burden shifts back to the plaintiff to produce evidence supporting jurisdiction. See Meier ex rel. Meier v. Sun Int'l Hotels, Ltd., 288 F.3d 1264, 1268 (11th Cir. 2002); see also Posner, 178 F.3d at 1214 (“The plaintiff bears the burden of proving ‘by affidavit the basis upon which jurisdiction may be obtained’ only if the defendant challenging jurisdiction files ‘affidavits in support of his position.’”).

III. Analysis “A federal district court in [Alabama] may exercise personal jurisdiction over a nonresident defendant to the same extent that [an Alabama] court may, so long as the exercise is consistent with federal due process requirements.” Licciardello v. Lovelady, 544 F.3d 1280, 1283 (11th Cir. 2008). Under its long-arm statute, “Alabama permits its courts to exercise jurisdiction over nonresidents to the fullest extent allowed under the Due Process Clause of the Fourteenth Amendment to the Constitution.” Ruiz de Molina v. Merritt & Furman Ins. Agency, Inc., 207 F.3d 1351, 1355-56 (11th Cir. 2000) (citing Martin v. Robbins, 628 So.2d 614, 617 (Ala. 1993)); see also Ala. R. Civ. P. 4.2 (permitting jurisdiction over nonresident defendants on any basis “not inconsistent with the constitution of this state or the Constitution of the United States”). Thus, this court may exercise personal jurisdiction over a defendant so long as jurisdiction is consistent with federal due process principles. The Supreme Court has recognized two types of personal jurisdiction consistent with the Fourteenth Amendment's Due Process Clause—general jurisdiction and specific jurisdiction. See

Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915, 923-24 (2011). In considering whether personal jurisdiction complies with due process, the court must consider “whether the defendant has ‘certain minimum contacts with [the state] such that the maintenance of the suit does not offend traditional notions of fair play and substantial justice.’” Waite v. All Acquisition Corp., 901 F.3d 1307, 1312 (11th Cir. 2018) (quoting Int'l Shoe Co. v. Washington, 326 U.S. 310, 316 (1945)). A defendant subject to general jurisdiction in a forum may be sued in that forum on all claims against it, even if the claims have no connection to the forum. Id. at 919. By contrast, a defendant that is subject only to specific jurisdiction may only be sued with respect to claims that arise out of, or relate to, the defendant’s contacts with the forum. Id. at 923-24. In this case,

Plaintiffs have conceded that they cannot establish either general or specific jurisdiction over A.O. Smith. A. General Jurisdiction For general jurisdiction to exist, the defendant's “affiliations with the State” must be “so continuous and systematic as to render [it] essentially at home in the forum State.” Daimler AG v. Bauman, 571 U.S. 117, 127 (2014). Under Daimler, corporations are subject to general jurisdiction where they are incorporated or where they have their principal place of business. 571 U.S. at 137. In this case, A.O.

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Bluebook (online)
State Farm and Casualty Company v. Broan-Nutone LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-farm-and-casualty-company-v-broan-nutone-llc-alnd-2022.