Monday, June 19, 2006

M.D. Ala. Rejects Personal Jurisdiction over Members of Council of Lloyd's

Per Redmon v. Society and Corp. of Lloyds, --- F.Supp.2d ----, 2006 WL 1635435 (M.D.Ala. Jun. 15, 2006):

[Redmon, a former professional football player, initiated this insurance coverage dispute in Alabama state court, naming, inter alia, Members of the Council of Lloyds of London in addition to underwriters of his disability insurance. The question was whether Alabama could exercise personal jurisdiction over the Council Members of Lloyds]

In the instant transactions, the Council Member defendants did not individually or collectively engage in any activity subjecting them to general or specific personal jurisdiction in Alabama. Sixteen of the eighteen Council Members have never been to Alabama. The other two Council Members have only been to Alabama once, as an agent in an unrelated matter. None of the Council Members' contacts with Alabama are sufficient to be deemed "continuous and systematic" such that the Council Members reasonably anticipated being haled into Alabama courts.Straining to extend the reach of this Court, Redmon relies upon Lloyd's contacts with the forum in order to subject the individual Council Members to personal jurisdiction in Alabama. However, a court cannot exercise personal jurisdiction over a defendant solely on the basis of an employer's contacts with the forum. Williams Elec. Co. v. Honeywell, Inc., 854 F.2d 389, 391-92 (11th Cir.1988); see also Painewebber, Inc. v. Chase Manhattan Private Bank (Switz.), 260 F.3d 453 (5th Cir.2001). Moreover, "[a]n officer who has never been in Alabama nor conducted personal business in the state through an alter ego or through personal agents, may not be subject to jurisdiction in Alabama." South Alabama Pigs, 305 F.Supp.2d at 1260. [FN9] Due to the business structure of Lloyd's of London, a connection between the Council Members and Alabama is even more tenuous.


Post a Comment

<< Home