Mohazzabi v. Mohazzebi

Background

Behrooz Mohazzabi filed a state-court lawsuit against Behzad Mohazzebi, alleging breach of contract and fraud. Behrooz alleged that he loaned $200,000 to a third brother, Dariush Mohazzebi, and that Behzad orally guaranteed repayment of the loan and interest. Behrooz alleged that Dariush failed to repay the loan and that Behzad failed to pay the remaining balance under the alleged guarantee.

After Behzad removed the case to federal court, he moved to dismiss for lack of personal jurisdiction and failure to state a claim. Behzad submitted a declaration stating that he had lived in Florida since November 2009, had previously lived in New Jersey, and had never been a California resident or citizen, worked in California, maintained a California business or office, or held a California bank account. He also stated that he had not met Behrooz in California during the events alleged in the complaint. Behrooz’s complaint did not allege specific contacts between Behzad and California. In later filings, Behrooz asserted that Behzad visited his daughters in Los Angeles.

Personal Jurisdiction

Personal jurisdiction is a court’s authority to hear a case against a particular defendant. The court explained that California’s jurisdictional reach extends as far as the federal Constitution permits, but due process requires sufficient “minimum contacts” between the defendant and California.

The court found no general jurisdiction. General jurisdiction requires continuous and systematic business contacts with the state. The complaint did not allege such contacts, and Behzad’s declaration stated that he had never been employed in California and had no California offices or bank accounts.

The court also found no specific jurisdiction. For the contract claim, the court applied the purposeful-availment test, which asks whether the defendant deliberately engaged in activities in the forum state or invoked the benefits and protections of its laws. The court concluded that the alleged oral agreement with a California resident and the alleged promise to send money to California were too limited and indirect to establish a substantial California connection.

For the fraud claim, the court applied the purposeful-direction test. That test asks whether the defendant committed an intentional act expressly aimed at California that caused harm the defendant knew was likely to occur there. The court concluded that Behrooz had not alleged that Behzad expressly aimed conduct at California. The court also stated that Behrooz’s status as a California resident could not, by itself, establish jurisdiction, and that Behzad’s visits to California to see his daughters would not provide a basis for jurisdiction.

Other Motion and Disposition

Behzad moved to strike Behrooz’s sur-reply because Behrooz filed it without permission. In light of Behrooz’s self-represented status, the court granted him permission to file the sur-reply and denied Behzad’s motion to strike it.

The court granted Behzad’s motion to dismiss for lack of personal jurisdiction. Because the court found that it lacked personal jurisdiction over Behzad, it did not address Behzad’s motion to dismiss for failure to state a claim. Judge Susan Illston vacated the scheduled hearing and resolved the motions without oral argument.