Matthew v. Flakt Woods Group SA
Annotate this CaseThe issue on appeal in this case came from a decision that dismissed a complaint against a foreign business entity for lack of personal jurisdiction. The foreign company allegedly conspired with other defendants to divest appellant of his interest in a lucrative joint venture. That plan was accomplished, in part, by causing the dissolution of a Delaware limited liability company co-founded by appellant. Under the "conspiracy theory" of personal jurisdiction, a plaintiff must allege facts from which one can infer that a foreign defendant knew or should have known that the conspiracy would have a Delaware nexus. The trial court found that the foreign company did not know about the Delaware connection until after the limited liability company had been dissolved. As a result, the trial court dismissed for lack of personal jurisdiction. Upon review, the Supreme Court reversed finding that the trial court's analysis was flawed in two respects: (1) the applicable standard is whether the foreign entity knew or should have known that it was conducting activity in Delaware (here, even if the record facts did not establish that appellee knew about the dissolution before it occurred, they established that appellee should have known that it was dealing with a Delaware company); (2) the conspiracy did not begin or end with the dissolution of the Delaware company (appellee learned that its business partner had been a Delaware entity shortly after the dissolution, and the alleged conspiracy continued long after that date).
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