Bluetarp Fin., Inc. v. Matrix Constr. Co., No. 12-1338 (1st Cir. 2013)Annotate this Case
Matrix Construction Co. was a South Carolina corporation with its principal place of business in South Carolina. Matrix was the general contractor on a project to renovate schools in South Carolina. Matrix hired Contract Supply as a subcontractor. Contract Supply had a relationship with BlueTarp Financial, a company providing commercial credit to the construction industry that had its principal place of business in Maine. After Matrix accepted Contract Supply's bid, Matrix signed BlueTarp's account agreement, which stated that disputes would be governed by the laws of Maine. Matrix later learned that Contract Supply was not paying its suppliers and stopped paying Contract Supply. BlueTarp filed this action for breach of contract and unjust enrichment in the federal district court for the District of Maine invoking diversity jurisdiction. The district court dismissed the case for lack of personal jurisdiction over Matrix. BlueTarp appealed, arguing that the forum selection clause in the account agreement authorized jurisdiction in the Maine district court and, in any event, Matrix had sufficient connections with Maine to satisfy the personal jurisdiction requirements. The First Circuit Court of Appeals reversed, holding that, having found the relatedness, purposeful availment, and reasonableness factors satisfied, the district court had personal jurisdiction over Matrix.