Stewart v. Marathon Petroleum Co. LP

326 F. Supp. 3d 284
CourtDistrict Court, E.D. Louisiana
DecidedJune 29, 2018
DocketCIVIL ACTION No. 17-7775
StatusPublished
Cited by5 cases

This text of 326 F. Supp. 3d 284 (Stewart v. Marathon Petroleum Co. LP) is published on Counsel Stack Legal Research, covering District Court, E.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Stewart v. Marathon Petroleum Co. LP, 326 F. Supp. 3d 284 (E.D. La. 2018).

Opinion

LANCE M. AFRICK, UNITED STATES DISTRICT JUDGE

Before the Court are two motions1 to dismiss for lack of personal jurisdiction pursuant to Federal Rule of Civil Procedure 12(b)(2) -one filed by defendant Marathon Petroleum Company LP ("Marathon") and the other by defendants Polar Corporation and Polar Tank Trailer, LLC ("Polar Tank Trailer") (collectively, "the Polar defendants"). For the following reasons, both motions are granted.

I.

Plaintiff Eddie Stewart, III ("Stewart"), a resident of Louisiana, is a commercial truck driver.2 On August 10, 2016, Stewart was assigned a job transporting a chemical from Michigan to the Gulf Coast using a tanker-trailer ("the trailer") manufactured by the Polar defendants.3 On August 11, pursuant to his superior's directions, Stewart arrived at Marathon's oil refinery in Detroit, where Marathon employees allegedly loaded the trailer with the incorrect chemical.4 On Marathon personnel's instructions, Stewart left the refinery after the loading was complete and continued on his route.5 Shortly thereafter, the trailer exploded on the side of the interstate in Ohio, allegedly causing Stewart to suffer personal injuries.6

II.

The Court may require a nonresident defendant to appear before it, but its jurisdictional power is restricted by constitutional and statutory bounds. "A federal court may exercise personal jurisdiction over a nonresident defendant if (1) the forum state's long-arm statute confers personal jurisdiction over that defendant; and (2) the exercise of personal jurisdiction comports with the Due Process Clause of the Fourteenth Amendment." McFadin v. Gerber , 587 F.3d 753, 759 (5th Cir. 2009). Because the limits of Louisiana's long-arm statute are defined by the Fourteenth Amendment, the two inquiries become one, and the Court need only consider whether the constitutional requirements of due process have been met. See Guidry v. U.S. Tobacco Co., Inc. , 188 F.3d 619, 624 (5th Cir. 1999) (citation omitted); see also La. Rev. Stat. Ann. § 13:3201.

Those requirements permit a court to exercise jurisdiction over a nonresident defendant when (1) that defendant establishes "minimum contacts" with the forum state, thereby "purposefully avail[ing]" itself of that state's benefits and *288protections; and (2) exercising jurisdiction over that defendant does not offend "traditional notions of fairy play and substantial justice." Latshaw v. Johnston , 167 F.3d 208, 211 (5th Cir. 1999) (quoting Int'l Shoe Co. v. Wash. , 326 U.S. 310, 316, 66 S.Ct. 154, 90 L.Ed. 95 (1945) ). The connection between the defendant's conduct and the forum state "must be such that he should reasonably anticipate being haled into court" there. Id.

The U.S. Supreme Court has divided personal jurisdiction into two types-specific or "conduct-linked" jurisdiction and general or "all-purpose" jurisdiction. Daimler AG v. Bauman , 571 U.S. 117, 122, 134 S.Ct. 746, 187 L.Ed.2d 624 (2014) ; Sangha v. Navig8 ShipManagement Private Ltd. , 882 F.3d 96, 101 (5th Cir. 2018). The former depends on a connection between the forum state and the underlying controversy, permitting courts to exercise jurisdiction over a nonresident defendant when that defendant has "purposefully directed" his activities at the forum state "and the litigation results from alleged injuries that arise out of or relate to those activities." Burger King Corp. , 471 U.S. 462, 472, 105 S.Ct. 2174, 85 L.Ed.2d 528 (1985) (emphasis added); see also Goodyear Dunlop Tires Operations S.A. v. Brown , 564 U.S. 915, 919, 131 S.Ct. 2846, 180 L.Ed.2d 796 (2011).

Thus, specific jurisdiction is a claim-specific inquiry and involves cases in which the defendant's forum-related activities give rise to the facts that form the basis of the lawsuit. The Fifth Circuit has articulated the following analysis for determining whether specific jurisdiction over a nonresident defendant is proper:

(1) whether the defendant has minimum contacts with the forum state, i.e., whether it purposely directed its activities toward the forum state or purposefully availed itself of the privileges of conducting activities there; (2) whether the plaintiff's cause of action arises out of or results from the defendant's forum-related contacts; and (3) whether the exercise of personal jurisdiction is fair and reasonable.

Monkton Ins. Servs., Ltd. v. Ritter , 768 F.3d 429, 432 (5th Cir. 2014).

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326 F. Supp. 3d 284, Counsel Stack Legal Research, https://law.counselstack.com/opinion/stewart-v-marathon-petroleum-co-lp-laed-2018.