Eagle Tech. v. Expander Americas, Inc., No. 14-1646 (8th Cir. 2015)
Annotate this CaseExpander Global conducts no business and is merely a holding company for its wholly owned subsidiary, Expander SystemSweden, another Swedish corporation. Expander Sweden wholly owns Expander Americas. Those companies manufacture industrial pins used in heavy machinery. In 2010, Eagle entered into an Independent Contractor Agreement with Expander Americas to provide consulting services. The Agreement led to a relationship between Global and Bakker, Eagle’s sole owner, who acted as a project manager and as secretary of the Global Board of Directors. In 2011, Global terminated Bakker from his positions and its agreement with Eagle. Eagle sued Expander Americas, alleging breach of contract and promissory estoppel; Bakker sued Global for quantum meruit. The district court dismissed the quantum meruit action for lack of personal jurisdiction, finding that Global did not have the requisite minimum contacts with Missouri to be subject to its Long-Arm Statute or to satisfy due process. It was not licensed to do business in the state; it did not advertise within the state; it did not send employees to the state; and no money was received or sent to the state. The court granted Expander Americas summary judgment on the remaining claims, based on the statute of frauds. The Eighth Circuit affirmed.
Court Description: Civil case - Contracts. Plaintiff Bakker did not carry his burden of establishing a prima facie case of personal jurisdiction over defendant Expander Global; nor did the district court err in granting defendants' motion for summary judgment on plaintiffs' remaining contract claim as the documents plaintiffs relied on to establish the existence of a contact did not satisfy the writing requirements of Arizona's statute of frauds.
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