Peters Broadcast Engineering, Inc. v. 24 Capital, LLC, No. 21-3849 (6th Cir. 2022)
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Capital, a New York LLC with its principal place of business in New York, sued Peters, an Indiana corporation with its principal place of business in Indiana, for breach of contract and received a judgment by confession in New York state court. Peter then brought suit in the Southern District of Ohio, alleging that Capital and its Operations Manager, a resident of Florida. engaged in a scheme that violated RICO, 18 U.S.C. 1962.
The Sixth Circuit affirmed dismissal for lack of jurisdiction, adopting the “forum state approach.” Service over out-of-district defendants is governed by 18 U.S.C. 1965(b), which provides that if “other parties residing in any other district be brought before the court, the court may cause such parties to be summoned, and process for that purpose may be served in any judicial district.” Section 1965 in its entirety “does not provide for nationwide personal jurisdiction over every defendant in every civil RICO case, no matter where the defendant is found.” Section 1965(a) grants personal jurisdiction over an initial defendant to the district court for the district in which that person resides, has an agent, or transacts his affairs; nationwide jurisdiction hinges on whether at least one defendant has minimum contacts with the forum state. Peters did not assert sufficient facts to establish that the court had personal jurisdiction over either defendant and did not specifically allege how the claims arose from conduct within Ohio.
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