Urquhart-Bradley v. Mobley, No. 19-7116 (D.C. Cir. 2020)Annotate this Case
The DC Circuit vacated the district court's dismissal of plaintiff's claims of employment discrimination against Cushman & Wakefield's Chief Executive Officer of the Americas for lack of personal jurisdiction based on the fiduciary shield doctrine.
The court held that the fiduciary shield doctrine lacks any basis in either the Due Process Clause or the transacting-business prong of the District of Columbia's long-arm statute, D.C.CODE 13-423(a)(1). The court also held that the district court's dismissal erroneously denied plaintiff's request in the alternative for limited jurisdictional discovery. Accordingly, on remand, the district court may either (i) determine on the current record that defendant's suit-related contacts (made in his capacity as CEO of the Americas and otherwise) satisfy the minimum-contacts standard, or (ii) grant jurisdictional discovery to permit development of the record on defendant's contacts with the District of Columbia.