Santamaria v. Hilton Worldwide, Inc.

Background

Wilmer Santamaria sued Hilton Worldwide, Inc. and HLT Existing Franchise Holding, LLC for injuries he allegedly suffered in August 2019 at the Hilton Fort Lauderdale Marina Hotel in Florida. He alleged that scalding water in his hotel-room shower caused serious burns. He primarily received medical treatment in New York, where he resides with his wife.

The defendants removed the case to federal court and moved to dismiss under Federal Rule of Civil Procedure 12(b)(2), which permits dismissal when the court lacks personal jurisdiction over a defendant. Santamaria also moved to amend the complaint to substitute Hilton Management LLC as the sole defendant. The defendants asserted that Hilton Management LLC was the proper party because it owned and operated the Florida hotel.

Santamaria alleged that the defendants were organized under New York law and conducted business in New York. The defendants submitted materials showing that they were Delaware entities with their principal places of business in Virginia. The opinion states that Santamaria did not contest those facts.

Personal Jurisdiction

The court explained that personal jurisdiction is the court’s authority over a defendant. In a diversity case, the court first examines whether New York’s long-arm statute permits jurisdiction and then considers whether jurisdiction is consistent with constitutional due process.

Specific Jurisdiction

Specific jurisdiction applies when the lawsuit arises from a defendant’s activities in the forum state. The court found no basis for it under any of the four relevant provisions of New York’s long-arm statute.

First, Santamaria did not allege that his claims arose from the defendants’ business transactions in New York. Second, he did not allege that the defendants committed a tort in New York. His claims concerned the alleged failure to maintain a shower in Florida. Third, although he received treatment in New York, the injury-causing event occurred in Florida, so the court found no injury in New York sufficient for jurisdiction under the statute. Fourth, the property connected to the claims was in Florida, not New York.

General Jurisdiction

General jurisdiction allows a court to hear any claim against a corporation, even if the claim arose elsewhere. The court explained that constitutional due process generally requires a corporation to be essentially at home in the forum state, ordinarily where it is incorporated or has its principal place of business.

The court found that Santamaria’s allegations that the defendants were authorized to do business and conducted business in New York were insufficient. It also declined to accept his allegation that the defendants were organized under New York law because that allegation conflicted with other allegations and with the defendants’ formation documents. The court concluded that the defendants’ New York contacts did not satisfy the constitutional standard for general jurisdiction.

Amendment Request and Disposition

The court denied Santamaria’s motion to amend the complaint because personal jurisdiction over Hilton Management LLC would also be absent for the same reasons. Judge Valerie Caproni granted the defendants’ motion to dismiss for lack of personal jurisdiction, denied Santamaria’s motion to amend the complaint, and directed the clerk to terminate the case.