Country Inn & Suites By Radisson, Inc. v. Alexandria Motels, Inc.

Background

Country Inn & Suites By Radisson, Inc. said it entered into a hotel-system license agreement with Alexandria Motels, Inc. in 2012. It also alleged that Lake Country Motels, LLC gave a corporate guarantee and that Vibha Patel and Jaimini Patel gave personal guarantees. After Country Inn gave Alexandria Motels notice of default, the license agreement was terminated in 2019.

Country Inn alleged that Alexandria Motels breached the license agreement, that the other defendants breached their guarantees, and that the defendants continued using Country Inn’s trademarks after termination. Its complaint asserted six counts: claims for unpaid fees, lost future profits, post-termination obligations, trademark infringement, false designation of origin or federal unfair competition, and attorneys’ fees. Jaimini Patel had separately claimed that she did not sign a personal guarantee, and the court had dismissed the claims against her without prejudice in late 2020 based on a stipulation.

Motions and jurisdiction

Country Inn moved for summary judgment, but said it was voluntarily dismissing its federal trademark claims, Counts IV and V, and sought judgment only on its contract and attorneys’ fees claims, Counts I–III and VI. Country Inn did not identify the procedural basis for dismissing Counts IV and V. No stipulation of dismissal was filed, no request for dismissal on terms was made, and no amended complaint was proposed. The remaining defendants stated that Country Inn had dismissed or declined to pursue its federal claims. Country Inn later said it dismissed those claims partly because the defendants stopped using its marks after the complaint was filed.

The court explained that removing the federal claims could require dismissal for lack of subject-matter jurisdiction or could permit the court to decline supplemental jurisdiction over the remaining state-law claims. Supplemental jurisdiction is a court’s authority to hear related state-law claims alongside federal claims. Country Inn made no argument for exercising that authority, and the court found no reason to do so.

Ruling

The court dismissed the action without prejudice rather than deciding the merits of Country Inn’s contract, guarantee, or attorneys’ fees claims. The order directed the Clerk of Court to terminate Docket No. 78 and directed that judgment be entered accordingly. Judge Joan N. Ericksen did not grant or deny Country Inn’s summary-judgment motion on the merits.