Picot v. Weston, No. 12-17098 (9th Cir. 2015)
Annotate this CasePlaintiff, a resident of California, and Defendant, a resident of Michigan, worked together with a third man to develop and market an electrolyte for use in hydrogen fuel cells. When Plaintiff and the third man sold the electrolyte technology without telling Defendant, Defendant threatened to sue if he was not paid what he claimed was his one-third share of the proceeds under an oral agreement. Thereafter, Plaintiff sued Defendant in California seeking a declaration that no oral agreement existed between the parties and for damages for intentional interference with a sales contract. The district court dismissed the suit, concluding that it lacked jurisdiction over Defendant on either of the two claims. The Supreme Court affirmed, holding that because Defendant neither purposefully availed himself of the privilege of conducting activities in California nor expressly aimed his conduct at California, the district court did not err in dismissing the case for lack of personal jurisdiction.
Court Description: Personal Jurisdiction. The panel affirmed the district court’s dismissal for lack of personal jurisdiction of a diversity action alleging tort and contract claims. The plaintiff, a resident of California, brought the action against the defendant, a resident of Michigan, seeking a declaration that no oral agreement was made, and seeking damages for intentional interference with the parties’ sales contract. The panel held that the defendant neither purposefully availed himself of the privilege of conducting activities in California nor expressly aimed his conduct at California. The panel concluded, therefore, that the district court did not err in dismissing for lack of specific personal jurisdiction.
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