Hawkeye Gold, LLC v. China National Materials, No. 22-2800 (8th Cir. 2023)
Annotate this CaseIn this case, the United States Court of Appeals for the Eighth Circuit affirmed the decision of the United States District Court for the Southern District of Iowa to dismiss the lawsuit of Iowa-based livestock feed seller Hawkeye Gold, LLC against China National Materials Industry Import and Export Corporation, also known as Sinoma, for lack of personal jurisdiction. Hawkeye Gold sued Sinoma to recover an unpaid default judgment it obtained against Sinoma's now-defunct wholly owned United States subsidiary, Non-Metals, Inc., for breach of a contract to purchase livestock feed. After six years of litigation, the District Court dismissed the case because it did not have personal jurisdiction over Sinoma, a decision which Hawkeye Gold appealed. The Appeals Court, after reviewing the evidence, agreed with the District Court's conclusion that Sinoma had insufficient minimum contacts with Iowa to support personal jurisdiction. The Court also rejected Hawkeye Gold's argument that Sinoma was a party to the contract or that Non-Metals was the alter-ego of Sinoma. Furthermore, the Court affirmed the District Court's denial of Hawkeye Gold's request for sanctions against Sinoma for alleged discovery violations.
Court Description: [Loken, Author, with Gruender and Benton, Circuit Judges] Civil case - Contracts. Defendant Sinoma's motion to set aside a default judgment was not a Rule 12 motion, and Sinoma preserved its personal jurisdiction by raising it in answers to plaintiff's complaints filed after the default judgment was set aside for improper service; the district court record was sufficient to require plaintiff to establish personal jurisdiction by a preponderance of the evidence, and it failed to do so; Sinoma was not a party to the contract in question, so it was not bound by the "Consent to Jurisdiction" clause of the contract; Non-Metals, the contracting party, was not an alter-ego for Sinoma and there is no evidence Sinoma had the necessary contacts with Iowa for plaintiff to assert personal jurisdiction over it; the district court did not abuse its discretion in denying plaintiff's Rule 37 motion for sanctions.
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