Employment Agreements and Email Exchanges Insufficient to Establish Personal Jurisdiction

The World in U.S. Courts: Summer 2013 - Personal Jurisdiction

Stiaes v. GEORXT, Inc. (U.S. District Court, E.D. La, June 18, 2013)

A former employee sued GEORXT, Inc. under maritime law and the Oceanographic Research Vessels Act for an injury to his hand. GEORXT moved to dismiss for lack of personal jurisdiction, arguing that, as a corporation organized under the laws of the British Virgin Islands, it had insufficient contacts with Louisiana. The plaintiff alleged GEORXT could be sued because it sent him an offer of employment in Louisiana and executed the employment agreement while the plaintiff resided in Louisiana through a series of emails.

The court granted the motion to dismiss and transferred the case to West Virginia, where GEORXT had greater contacts. The court held that entering into a contract and exchanging emails was not sufficient conduct to establish minimum contacts with Louisiana to support personal jurisdiction.

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