Theodore Justice v. Ally Financial, Inc., et al.

CourtDistrict Court, E.D. Michigan
DecidedMarch 3, 2026
Docket4:24-cv-11936
StatusUnknown

This text of Theodore Justice v. Ally Financial, Inc., et al. (Theodore Justice v. Ally Financial, Inc., et al.) is published on Counsel Stack Legal Research, covering District Court, E.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Theodore Justice v. Ally Financial, Inc., et al., (E.D. Mich. 2026).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

THEODORE JUSTICE, Case No. 24-11936

Plaintiff, F. Kay Behm v. United States District Judge

ALLY FINANCIAL, INC., et al., Curtis J. Ivy, Jr. United States Magistrate Judge Defendants. ____________________________/

OPINION AND ORDER ACCEPTING AND ADOPTING THE MAGISTRATE JUDGE’S NOVEMBER 24, 2025 REPORT AND RECOMMENDATION (ECF No. 58) AND GRANTING SAMSUNG’S MOTION TO DISMISS (ECF No. 49)

Currently before the court is Magistrate Judge Ivy’s November 24, 2025 Report and Recommendation. ECF No. 58. Judge Ivy recommends that Defendant Samsung Electronics America’s Motion to Dismiss (ECF No. 49) be granted for lack of personal jurisdiction under Federal Rule of Civil Procedure 12(b)(2). For the reasons explained below, the court accepts and adopts that report and recommendation in full, overrules Plaintiff’s objections, grants the motion, and dismisses Samsung from this matter for lack of personal jurisdiction. I. PROCEDURAL HISTORY Plaintiff Theodore Justice originally filed this case against Ally

Financial Inc. only on July 26, 2025 (ECF No. 1). After permission was granted to file an amended complaint (ECF No. 30), Justice filed a First Amended Complaint (ECF No. 31), which added Defendant Samsung

Electronics, Inc. This was subsequently followed by a Second Amended Complaint (SAC) (ECF No. 40) against both Ally and Samsung. Samsung filed a motion to dismiss the SAC’s claims against it for

lack of personal jurisdiction under Federal Rule of Civil Procedure 12(b)(2) and for failure to state a claim under 12(b)(6). ECF No. 49. Plaintiff responded to that motion. ECF No. 50. Magistrate Judge Ivy

issued a report and recommendation on November 24, 2025, recommending this court grant the motion and dismiss Samsung from this action under Rule 12(b)(2). ECF No. 58, PageID.788. Plaintiff

timely objected to that report and recommendation. ECF No. 59.1 On the same day he issued the report and recommendation, the Magistrate Judge granted Plaintiff’s motion to file a Third Amended

Complaint (TAC) (ECF No. 44), and ordered Plaintiff to “file his Third

1 Plaintiff also filed a motion to transfer Samsung’s claims to the District of New Jersey. ECF No. 61. But he withdrew that motion shortly afterward, so the court proceeds on the R&R and objections as presented. ECF No. 62. Amended Complaint (with his exhibits) [ECF No. 44-1 and subsequent

exhibits] within fourteen days of” November 24, 2025. ECF No. 57, PageID.768. That Third Amended Complaint was then filed at ECF No. 60. Magistrate Judge Ivy’s report and recommendation is based on both

the SAC and the (then proposed) TAC, because the allegations in the two were functionally equivalent as to Samsung.2 II. FACTUAL BACKGROUND

Given that on this motion, the issue is only Defendant Samsung’s motion to dismiss, the court limits its recitation of the facts to those involving Samsung.

2 “If some of the defects raised in the original motion remain in the new pleading, the court simply may consider the motion as being addressed to the amended pleading.” Klein by Klein v. Caterpillar, Inc., 581 F. Supp. 3d 912, 919 (E.D. Mich. 2022) (quoting Yates v. Applied Performance Techs., Inc., 205 F.R.D. 497, 499 (S.D. Ohio 2002)) (citation modified). This is particularly the case if the amended pleadings are “substantially identical to the original complaint.” Id. (citation modified). In this vein, no party has objected to the R&R’s reliance on the proposed TAC referenced in its text (at ECF No. 44-1) rather than the subsequently filed TAC at ECF No. 60. They are not the same document – though Magistrate Judge Ivy ordered that they be the same document in ECF No. 57. However, the court has reviewed the two documents and there do not ultimately appear to be material differences for purposes of this motion. And if there are material differences, it was Plaintiff’s job to object and explain those differences. Plaintiff had, after all, an equivalent amount of time to file his amended complaint and to object to the R&R. See ECF Nos. 57, 58. Lacking any record for why these documents are different or any explanation of the substantive differences between them for purposes of this motion, the court will analyze the issues as presented by the Magistrate Judge and the parties. Plaintiff, who is a resident and citizen of North Carolina, alleges

that he purchased a Samsung cell phone and various accessories in North Carolina; this purchase was allegedly financed through co- Defendant Ally Financial, Inc., which is located in Michigan. ECF No.

60, PageID.816.3 A subsequent Samsung product update, however, rendered the accessories incompatible with the phone. Id. at PageID.817. Plaintiff purportedly contacted Samsung multiple times to

initiate a return and request a Return Merchandise Authorization (“RMA”) form for the now-incompatible accessories. Id. Plaintiff claims that Samsung “agreed to accept return of the phone but refused to issue

an RMA for the accessories and denied warranty coverage.” Id. He ultimately made full payment to Ally Financial for the Samsung products. See id. The remaining allegations in the TAC focus on Ally’s

allegedly unlawful conduct. III. STANDARD OF REVIEW A party may object to a magistrate judge’s report and

recommendation on dispositive motions, and a district judge must

3 The court cites the operative TAC (ECF No. 60) rather than the proposed TAC (ECF No. 44-1). resolve proper objections under a de novo standard of review. 28 U.S.C.

§ 636(b)(1)(B)-(C); Fed. R. Civ. P. 72(b)(1)-(3). This court “may accept, reject or modify, in whole or in part, the findings or recommendations made by the magistrate judge.” Id. “For an objection to be proper,

Eastern District of Michigan Local Rule 72.1(d)(1) requires parties to ‘specify the part of the order, proposed findings, recommendations, or report to which [the party] objects’ and to ‘state the basis for the

objection.’” Pearce v. Chrysler Grp. LLC Pension Plan, 893 F.3d 339, 346 (6th Cir. 2018). Objections that dispute the general correctness of the report and recommendation are improper. Miller v. Currie, 50 F.3d

373, 380 (6th Cir. 1995). Moreover, objections must be clear so that the district court can “discern those issues that are dispositive and contentious.” Id. (citing

Howard v. Sec’y of Health and Human Servs., 932 F.2d 505, 509 (6th Cir. 1991)); see also Thomas v. Arn, 474 U.S. 140, 147 (1985) (explaining that objections must go to “factual and legal” issues “at the heart of the

parties’ dispute”). In sum, the objections must be clear and specific enough that the court can squarely address them on the merits. See Pearce, 893 F.3d at 346. And, when objections are “merely perfunctory responses . . . rehashing . . . the same arguments set forth

in the original petition, reviewing courts should review [a Report and Recommendation] for clear error.” Ramirez v. United States, 898 F.Supp.2d 659, 663 (S.D.N.Y. 2012); see also Funderburg v. Comm’r of

Soc. Sec., No. 15-10068, 2016 WL 1104466, at *1 (E.D. Mich. Mar.

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