Acuity v. Rex, LLC, No. 18-1735 (8th Cir. 2019)
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The Eighth Circuit affirmed the district court's orders requiring it to deposit $21 million in disputed insurance proceeds to maintain its federal statutory interpleader claim and dismissing Ronald Gean and the Estate of Jean Carol Gean for lack of personal jurisdiction in its declaratory judgment claims. The Geans are citizens of Michigan and were injured in an automobile accident in Illinois by a truck operated by Rex, a Missouri company.
The court agreed with the district court that subject matter jurisdiction was lacking because Acuity did not deposit the disputed amount into the court's registry. The court rejected Acuity's argument that the district court had personal jurisdiction over the Geans. Rather, the court held that the district court lacked personal jurisdiction over the Geans in the remaining declaratory judgment action.
Court Description: Gruender, Author, with Wollman and Shepherd, Circuit Judges] Civil case - Insurance. Acuity has not waived its right to appeal the district court's order requiring it to deposit $21 million into the court's registry by dismissing its interpleader claim as the motion to dismiss was involuntary in light of the court's ruling; subject-matter jurisdiction over Acuity's interpleader action is lacking because it did not deposit the disputed amount into the court's registry; the district court did not err in finding it did not have personal jurisdiction over the victims of the accident giving rise to this dispute. Judge Shepherd concurring in part and concurring in the judgment.
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