Becquer v. Mirantis, Inc.

Background

Pedro J. Becquer sued Mirantis, Inc. and Marque Teegardin, alleging tortious interference with his contract, business relationship, and/or reasonable expectations of economic advantage. The dispute arose from Becquer’s employment with Mirantis while he also remained employed by NICE Systems, Inc. Becquer resigned from Mirantis in January 2016 after deciding to remain with NICE. During a telephone call with Becquer, Teegardin was in Georgia. Teegardin then contacted NICE and disclosed Becquer’s dual employment. Becquer alleged that Teegardin encouraged NICE to terminate him and that NICE did so.

Teegardin moved to dismiss the claim against him for lack of personal jurisdiction. Teegardin was a Georgia resident and had been a Mirantis employee who indirectly supervised Becquer. He had traveled to Minnesota once for a one-day meeting with Becquer but otherwise did not travel to Minnesota during his employment with Mirantis. The opinion states that he no longer owned or leased property, held bank accounts, paid taxes, worked, maintained a mailing address, or was registered to vote in Minnesota.

Personal Jurisdiction

The court explained that Becquer had to make a prima facie showing that Minnesota could exercise personal jurisdiction over Teegardin. Because Minnesota’s long-arm statute extends as far as the Due Process Clause allows, the court focused on due process and whether Teegardin had sufficient minimum contacts with Minnesota.

For specific jurisdiction, the claim must arise from or relate to the defendant’s activities in the forum state. The court rejected Becquer’s reliance on Teegardin’s knowledge that Becquer lived and worked in Minnesota, Teegardin’s indirect supervision of Minnesota-based work, Teegardin’s one trip to Minnesota, and the fact that Becquer became unemployed in Minnesota. The court found that none of those contacts related to the alleged tort. The conduct alleged in the complaint was Teegardin’s call to NICE in New Jersey from Georgia after Becquer resigned from Mirantis. None of the alleged actions took place in Minnesota or were directed there.

Becquer also invoked the effects test, which can allow jurisdiction over a nonresident whose intentional conduct is expressly aimed at the forum and causes harm there. The court held that Becquer’s injury in Minnesota was insufficient because Teegardin’s conduct was directed at NICE in New Jersey, not at Minnesota. The court also stated that Teegardin’s knowledge that Becquer was a Minnesota resident was not enough. The opinion did not fully address general jurisdiction because Becquer provided little argument or legal support for it, but it noted that the record was insufficient to show Teegardin had continuous and systematic contacts with Minnesota.

Disposition

The court granted Teegardin’s motion to dismiss and ordered that Marque Teegardin be dismissed from the action. The ruling was based on the lack of personal jurisdiction and did not resolve the merits of Becquer’s tortious-interference allegations.