Smith v. Maryville University of Saint Louis

Background

Aimee L. Smith, a Minnesota resident, enrolled in Maryville University of Saint Louis’s online Master of Nursing Program and completed the first five semesters of the six-semester program. During the final semester, she completed a practicum and recorded her hours through Maryville’s online learning platform. After a dispute about her hours and the absence of an evaluation from the supervising practitioner, Maryville gave Smith a failing grade, denied her appeals, and dismissed her from the program for allegedly falsifying her hours in violation of its academic-integrity policy.

Smith sued Maryville in Minnesota state court in June 2019. She alleged that Maryville’s online student handbook formed a contract with its students and that Maryville breached that contract by failing to follow the handbook’s procedures before dismissing her. Maryville removed the case to federal court and moved to dismiss for lack of personal jurisdiction, meaning that Maryville argued the Minnesota court lacked authority to decide the case against it.

Personal Jurisdiction

The court considered whether Maryville had sufficient contacts with Minnesota under the state’s long-arm statute and the federal Constitution’s due-process requirements. The court addressed both general and specific personal jurisdiction.

The court concluded that it could not exercise general jurisdiction because Maryville was a Missouri nonprofit corporation with its registered offices and campus in St. Louis, Missouri, and appeared to have its principal place of business there. The court therefore treated Missouri, rather than Minnesota, as the place where Maryville was “at home.”

For specific jurisdiction, the court examined whether Smith’s claim arose from or related to Maryville’s Minnesota contacts and whether Maryville had purposefully established those contacts. Smith identified Maryville’s website and advertising, her Canvas username and password, the alleged student-handbook contract, and the letters, emails, and Skype call concerning her academic-integrity dispute.

The court held that Smith’s breach-of-contract claim did not arise from Maryville’s general Internet presence, alleged Minnesota-targeted advertising, or provision of access to Canvas. The advertisements and supporting materials appeared to show a generic national campaign rather than advertising specifically directed at Minnesota. The court also determined that these Internet contacts would not establish purposeful availment even if the claim had arisen from them.

The court recognized that the alleged contract and the communications concerning Smith’s academic-integrity dispute related to her claim. But it held that a contract with an out-of-state defendant and related communications are not automatically enough to establish specific jurisdiction. Here, the alleged contract was implicit in a handbook posted online for all students, did not require payments or performance in Minnesota, and contemplated only a limited number of communications if an academic-integrity dispute arose. Considering the contract and communications together, the court found that they did not have the required quality, nature, or quantity to show that Maryville purposefully availed itself of doing business in Minnesota. The court also found that Minnesota’s interest in providing a forum and the convenience of the parties did not overcome the lack of sufficient contacts; it noted that all witnesses except Smith appeared to be outside Minnesota.

Ruling

The court held that it lacked specific personal jurisdiction over Maryville. It granted Maryville’s motion to dismiss and dismissed the action without prejudice. The court did not decide the merits of Smith’s allegation that Maryville breached the student-handbook contract.