Sprague v. Office of the Chief Medical Examiner

Background

The order addressed personal jurisdiction and venue issues discussed during a pre-motion conference. The court understood that Ethan Sprague intended to assert claims for wrongful death, fraud, and concealment concerning the medical treatment and care provided to his mother during her final days and the documentation of that treatment and care.

Jurisdiction

The court concluded that it had subject-matter jurisdiction under the federal diversity statute because Sprague was a citizen of New York, each defendant was a citizen of Maine, and the amount in controversy exceeded $75,000.

The court nevertheless determined that it did not appear to have personal jurisdiction over any defendant. It found no basis for general jurisdiction and concluded that the claims did not arise from contacts with New York because the defendants were citizens of Maine and the conduct at issue occurred entirely in Maine. The court also stated that exercising jurisdiction would not satisfy constitutional due-process requirements.

Transfer

Under 28 U.S.C. § 1406(a), a federal court may transfer a case when personal jurisdiction or venue is improper if transfer serves the interest of justice. The court stated that dismissal motions based on lack of personal jurisdiction would likely succeed and would delay resolution. The Office of the Chief Medical Examiner and Northern Lights Mercy consented to transfer during the conference, and David T. Sprague later consented in a letter to the court.

Ruling

Judge Katherine Polk Failla ordered the Clerk of Court to transfer the action to the United States District Court for the District of Maine rather than dismiss it. The Clerk was also directed to terminate pending motions, adjourn remaining dates, and mail a copy of the order to Sprague. The order did not resolve the merits of the intended wrongful-death, fraud, or concealment claims.