Elsie Simmons v. National Railroad Passenger Corporation

Background

Elsie Simmons sued the National Railroad Passenger Corporation, also called Amtrak, Union Station Investco LLC, Ashkenazy Acquisition Corp., Jones Lang Lasalle Americas, Inc., and Interstate Cleaning Corporation for personal injuries. She alleged that on May 9, 2016, while traveling on an Amtrak train, she left the train during a stop at Union Station in Washington, D.C., used a women’s bathroom, and slipped and fell on water or another liquid on the floor.

Simmons originally filed the case in New York state court. Amtrak removed it to the Southern District of New York. The defendants then moved to dismiss under Federal Rule of Civil Procedure 12(b)(2), which permits dismissal when the court lacks personal jurisdiction—the legal authority to exercise power over a defendant.

Amtrak’s Personal-Jurisdiction Motion

The court held that the complaint alleged enough facts to show that Amtrak transacted business in New York. The complaint alleged that Amtrak operated railroads, stations, and related facilities in New York and sold tickets there and online to people in New York.

That showing was not enough, however. New York’s long-arm statute and constitutional due process also required a connection between Amtrak’s New York activities and Simmons’s claim. Simmons argued that she purchased her train ticket in New York and that Amtrak’s liability arose from a contract for safe passage. The court noted that the complaint did not actually allege that the ticket was purchased in New York, but held that even such an allegation would not establish jurisdiction. The alleged negligence, injury, and relevant events occurred in Washington, D.C., and the ticket purchase was not sufficiently related to the injury.

The court also rejected Simmons’s reliance on cases involving trademark infringement and shipments of infringing goods into New York. In those cases, the New York contacts directly related to the claims. Here, the alleged wrongful conduct and injury occurred outside New York. Amtrak’s motion to dismiss was therefore granted.

Request to Amend

Simmons requested permission to amend the complaint. The court denied that request because alleging that she purchased the ticket in New York would not establish personal jurisdiction, and the fundamental facts identified by the court—the alleged negligence and injury occurring in Washington, D.C.—would remain unchanged. The court concluded that an amendment would be futile, meaning it could not survive a dismissal motion.

Supplemental Jurisdiction and Remand

After granting Amtrak’s motion, the case involved only state-law claims against the remaining defendants. The court found that it lacked diversity jurisdiction because the complaint alleged that Ashkenazy Acquisition Corp. was organized under New York law and that Simmons was a New York resident.

The court had discretion to exercise supplemental jurisdiction, meaning authority to hear related state-law claims alongside federal claims. It declined to do so because the federal claim had been dismissed, discovery had not ended, no merits motions had been decided, and considerations of fairness, convenience, judicial efficiency, and respect for state courts favored returning the state-law dispute to state court.

Disposition

The court granted Amtrak’s motion to dismiss, denied Simmons’s request to amend the complaint, remanded the action to state court, and denied the remaining defendants’ motion to dismiss as moot. The Clerk was directed to close the motions and the case.