Garza v. Forquest Ventures, Inc.
Annotate this CaseForquest Ventures was formed to operate a placer mining enterprise in Helena, Montana. Ken Hagman relied on purported assay reports of the site allegedly performed by Advanced Analytical before incorporating Forquest. Following incorporation, Forquest sold or issued stock to investors, including Investors. Because there was little precious metal content at the site, Forquest realized no profits and Investors received no return on their investments. Emilio and Candice Garza, individually and on behalf of all similarly situated Forquest investors, sued. The Garzas then filed an amended complaint adding the other Investors as named plaintiffs. Forquest filed a third-party complaint against Advanced Analytical. The district court granted summary judgment to Investors on their Montana Securities Act (Act) claims and granted Advanced Analytical’s motion to dismiss. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) correctly determined that Investors timely asserted their claims under the Act; (2) did not err in determining that the non-Garza Investors’ claims relate back to the original complaint’s filing date; (3) correctly determined that there were no genuine issues of material fact regarding Forquest’s failure to use reasonable care in the sale of securities to Investors; but (4) erred in dismissing Advanced Analytical for lack of personal jurisdiction.
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