PREP Tours, Inc. v. American Youth Soccer Organization, No. 17-1223 (1st Cir. 2019)Annotate this Case
The First Circuit affirmed the order of the district court dismissing Plaintiff’s contract and tort claims for lack of personal jurisdiction, holding that the federal court in Puerto Rico lacked personal jurisdiction over Defendants.
Plaintiff, a Puerto Rico tour company, brought this diversity suit in the United States District of Puerto Rico, alleging that a California youth soccer organization and related defendants breached duties that the organization owed to Plaintiff under Puerto Rico contract and tort law. The allegations centered around Defendants’ acts of first requesting that Plaintiff make an offer for a potential soccer trip to Puerto Rico for some of the organization’s teams and their families and then declining after further communications to book the tour. The district court dismissed the claims for lack of personal jurisdiction. The First Circuit affirmed, holding that the exercise of specific jurisdiction in the forum over the out-of-forum defendants did not conform to the federal constitutional test.