Eighteen Seventy, et al. v. Jayson, No. 20-8015 (10th Cir. 2022)
Annotate this CaseOver four years, Plaintiffs-Appellants Eighteen Seventy, LP and the Marie Kennedy Foundation (the “Kennedy Entities” or “Entities”) lost more than $10 million they invested in CRUPE Pte. Ltd. (“CRUPE”) and its subsidiaries. CRUPE was a foreign company organized under the laws of Singapore and managed in Zurich, Switzerland. Believing that CRUPE’s co-founder and CFO, Defendant-Appellee Richard Jayson, induced their investment losses through misrepresentations and material omissions, the Kennedy Entities sued Jayson for gross negligence and breach of fiduciary duty in the U.S. District Court for the District of Wyoming. The Entities, both of which had their principal place of business in Wyoming, averred that Jayson surreptitiously used their financial support to compensate himself and another company co-founder while failing to provide the Kennedy Entities with information about CRUPE’s viability and the true nature of their investments. Jayson, a domiciliary and resident of the United Kingdom, moved to dismiss the Kennedy Entities’ suit, pursuant to Federal Rule of Civil Procedure 12(b)(2), arguing that the court lacked personal jurisdiction over him. The district court agreed with Jayson and dismissed the complaint. The Kennedy Entities appealed appeal, claiming the district court erred when it held Jayson lacked the requisite minimum contacts with Wyoming to afford the court personal jurisdiction. They contended Jayson purposefully directed activities at Wyoming by preparing investment documents that encouraged the Kennedy Entities’ investments and by communicating with the Entities’ owners about the investments. These contentions notwithstanding, the Tenth Circuit Court of Appeals affirmed the district court’s dismissal of this case for want of personal jurisdiction. “Although the Kennedy Entities meet the first prong of the purposeful direction test, they fail to satisfy the second: that is, they fail to show that Mr. Jayson expressly aimed his conduct at Wyoming.”
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