Personal Jurisdiction

Pruitt v. AAA Interstate Transportation, LLC, [Ms. 1200666, Jan. 21, 2022] __ So. 3d __ (Ala. 2022). The Court (Mitchell, J.; Parker, C.J., and Shaw, Bryan, and Mendheim, JJ., concur) affirms the Walker Circuit Court’s order granting AAA Interstate Transportation, LLC’s (“AAA”) motion to dismiss asserting lack of personal jurisdiction. In the spring of 2018, AAA transported a crane truck owned by Michels Machinery Co., Inc. (“Michels”) from Yukon, Oklahoma, to Michels’s facility in Las Vegas, Nevada. AAA did not perform any maintenance on the crane truck, never had any property interest in it, and had no further involvement with it after delivering it to Michels. Ms. *2. After Michels sold the crane truck to Jimmy’s Construction & Maintenance, Inc. (“Jimmy’s”), an Alabama corporation headquartered in Walker County, Jimmy’s hired Terry Pruitt to bring the crane truck from Nevada to Walker County. In Texas, one of the tires on the crane truck failed, causing it to roll over several times, resulting in severe and life-threatening injuries to Pruitt and his wife who accompanied him on the trip. Ms. *3.

The Court notes that “[w]e apply de novo review to rulings on motions to dismiss for lack of personal jurisdiction. Elliott v. Van Kleef, 830 So. 2d 726, 729 (Ala. 2002). And we review for excess of discretion trial courts’ decisions on the availability and scope of jurisdictional discovery. See Branded Trailer Sales, Inc. v. Universal Truckload Servs., Inc., 74 So. 3d 404, 411, 418-19 (Ala. 2011).” Ms. *8. The Court first rejects the Pruitts’ general jurisdiction argument, noting that “it is undisputed that AAA is organized under the laws of Colorado and has its principal place of business there, so neither of the first two conditions is met. Nor (on the allegations and record before us) does AAA have such continuous and systematic contacts with Alabama that it is at home here despite its out-of-state provenance and headquarters.” Ms. *10.

The Court also concludes that specific jurisdiction was lacking and notes “the touchstone of specific jurisdiction is whether the defendant has ‘purposefully avail[ed] itself of the privilege of conducting activities within the forum State,’” Ms. *12, quoting Ford Motor Co. v. Montana Eighth Judicial Dist. Ct., 592 U.S. ___, ___, 141 S. Ct. 1017, 1024 (2021)(some internal quotation marks omitted). The Court explains

[T]he only suit-related conduct by AAA is its conduct involving the crane truck in which the Pruitts were injured. But all AAA did with the crane truck was transport it from Oklahoma to Nevada for Michels three months before the Pruitts’ accident. The record shows that AAA had no knowledge of any Alabama business of Michels and that Michels did not sell the crane truck to Jimmy’s until some time after AAA delivered it to Nevada. In short, the Pruitts cannot point to any suit-related conduct of AAA directed at Alabama or any facts indicating that AAA should have anticipated that its transportation of the crane truck might lead to a suit in Alabama.

Ms. *13.

The Court also concludes the circuit court did not exceed its discretion in denying jurisdictional discovery

[A] plaintiff is not entitled to discovery to rebut a properly supported Rule 12(b)(2) motion if the plaintiff fails to “allege facts that would support a colorable claim of jurisdiction” or to offer more than “bare, attenuated, or unsupported assertions of personal jurisdiction.” Ex parte Lowengart, 59 So. 3d 673, 678 (Ala. 2010); see also Ex parte Gregory, 947 So. 2d 385, 390 (Ala. 2006); Troncalli Chrysler, 876 So. 2d at 468. In this case, the Pruitts actually obtained discovery in the form of AAA’s answers to their request for admissions, and the undisputed evidence before the circuit court abundantly showed that (for the reasons stated above) neither general nor specific personal jurisdiction over AAA could exist. There was no reason to believe that further evidentiary development was warranted.

Ms. *14.

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