Harrington v. Energy West, Inc.
Annotate this CasePlaintiff sued Defendant, a corporation, alleging wrongful discharge, negligent infliction of emotional distress, and defamation after his employment was terminated. The district court granted Defendant’s motion to dismiss for lack of subject-matter jurisdiction, determining that Ohio law governed Plaintiff’s claims. The Supreme Court vacated the district court’s dismissal and remanded for consideration of whether dismissal under the doctrine of forum non conveniens was appropriate, holding (1) the district court did not err in considering evidence outside the pleadings in disposing of Defendant’s motion to dismiss; but (2) the district court was incorrect to conclude that the application of Ohio law to Plaintiff’s claims requires dismissal for lack of subject-matter jurisdiction.
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