Pederson v. GoJet Airlines, LLC

Background

Nathaniel P. Pederson alleged four claims against GoJet Airlines, LLC and Trans States Holdings, Inc.: disability discrimination under the Americans with Disabilities Act, failure to provide a reasonable accommodation under that statute, violation of the Family and Medical Leave Act, and retaliation for trying to exercise his rights under that Act.

Pederson applied to become a GoJet flight attendant in December 2016. He attended training in Illinois, was hired as a trainee, and became a full-time flight attendant in April 2017. He worked primarily out of Chicago and sometimes worked out of Detroit on flights to Minneapolis. As part of his employment application, he signed a mutual arbitration agreement.

After a May 2018 automobile accident and seizure caused by epilepsy, Pederson requested and received leave under the Family and Medical Leave Act. Although his personal doctor later cleared him to return to work, GoJet required him to undergo a fit-to-fly medical examination. An aviation medical examiner determined that he was not fit for flight duty and could not perform the essential duties of a flight attendant. GoJet gave him the choice of unpaid medical leave or resignation. He chose unpaid medical leave and, according to the opinion, remained employed by GoJet while on that leave.

Motions and jurisdiction

The defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(2), which permits dismissal when a court lacks personal jurisdiction over a defendant. In the alternative, they moved to stay the case and compel arbitration. Personal jurisdiction is a court’s authority to decide a case involving a particular defendant.

The court considered general personal jurisdiction, which can allow a court to hear any claim against a corporation when the corporation is incorporated in the state, has its principal place of business there, or has exceptionally substantial connections making it essentially “at home” there. GoJet was incorporated in Delaware and had its principal place of business in Missouri. Trans States Holdings was also incorporated in Delaware and had its principal place of business in Missouri.

The court rejected the alleged contacts between GoJet and Minnesota. A letter listing the address of an Association of Flight Attendants representative in Minneapolis was not enough. An alleged interview of an applicant in Eagan, Minnesota, based on a posting on Glassdoor.com, was also insufficient because it was a single business transaction unrelated to the claims. The court further concluded that GoJet’s past service of Minneapolis did not make it subject to general jurisdiction in Minnesota; operating flights in a market does not automatically make an airline legally “at home” there.

The court also concluded that Pederson had not alleged a single contact between Trans States Holdings and Minnesota. It noted that GoJet’s contacts could not be attributed to its parent company without a showing that the parent controlled and dominated the subsidiary’s affairs, which Pederson had not made.

Ruling

The court held that it lacked personal jurisdiction over both defendants. It therefore granted Defendants’ Motion to Dismiss. Because the court lacked personal jurisdiction, it did not consider the merits of the motion to stay and compel arbitration and denied that motion as moot. The court ordered that the action be dismissed without prejudice.

The court noted that, if Pederson filed the action in an appropriate forum, it was uncertain whether arbitration would be required. It identified possible issues involving the Federal Arbitration Act’s exception for certain transportation workers and whether the later collective bargaining agreement covered the earlier dispute. Those issues were not decided in this order.