Laurel Gardens, LLC v. McKenna, No. 18-3758 (3d Cir. 2020)
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Plaintiffs sued 33 defendants, alleging “a widespread criminal enterprise ... involving numerous RICO [Racketeer Influenced and Corrupt Organizations Act] predicate acts," plus Pennsylvania law violations, asserting that the enterprise’s objective has been to inflict severe economic hardship to obstruct and discourage the plaintiffs from continuing in landscaping and snow removal services. The court dismissed the Iskens for lack of personal jurisdiction. The Iskens are Delaware residents and their business is a Delaware LLC with its principal place of business in Delaware.
The Third Circuit vacated, holding that 18 U.S.C. 1965(b), not 18 U.S.C. 1965(d) (the general jurisdiction provision), governs the exercise of personal jurisdiction and that the plaintiffs satisfy the statutory (and constitutional) requirements for the district court to exercise such jurisdiction over the Iskens. When a civil RICO action is brought in a district court where personal jurisdiction can be established over at least one defendant, summonses can be served nationwide on other defendants if required by the ends of justice. The plaintiffs alleged a multi-state scheme implicating defendants from Delaware, New Jersey, and Virginia, but roughly half of the 33 defendants are Pennsylvania residents or Pennsylvania entities with their places of business in Pennsylvania. The exercise of personal jurisdiction over defendants from a neighboring state does not offend traditional notions of fair play and substantial justice.
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