Eric & Co Trading Group LLC v. Mayweather
- Vyskocil
- 1:21-cv-08580
- U.S. District Court · Southern District of New York
- 6
In Eric & Co Trading Group LLC v. Mayweather, Judge Vyskocil denied default judgment and dismissed the case without prejudice for lack of personal jurisdiction.
Eric & Co Trading Group LLC’s claims against Floyd Joy Mayweather Jr. were dismissed without prejudice because the court found no personal jurisdiction in New York; the requested default judgment was denied.
What happened
Eric & Co Trading Group LLC sued Floyd Joy Mayweather Jr. for allegedly failing to pay $389,550 for jewelry bought on credit in Florida. Mayweather did not respond after being served, so the company asked for a default judgment.
The court first examined whether it had power over Mayweather, even though he had not appeared. It found that the transaction occurred in Florida, Mayweather lived in Florida, and the company had not shown that Mayweather himself had sufficient connections with New York. The company’s New York location and Mayweather’s knowledge of that connection were not enough.
Judge Mary Kay Vyskocil denied the motion for default judgment and dismissed the action without prejudice because the court lacked personal jurisdiction over Mayweather. The court also directed the clerk to close the case.
The detailed version
- Eric & Co Trading Group LLC v. Mayweather · No. 1:21-cv-08580
- Vyskocil
- Aug. 25, 2022
Background
Eric & Co Trading Group LLC brought claims against Floyd Joy Mayweather Jr. for breach of contract, quantum meruit, and unjust enrichment. The company alleged that Mayweather purchased jewelry worth $389,550 on credit during a visit to one of the company’s pop-up stores in Miami in June 2021. According to the amended complaint, Mayweather did not pay for the jewelry. The company also alleged that the parties had prior dealings in which Mayweather bought jewelry on credit and paid on time.
The company filed an affidavit stating that Mayweather had been served with the summons and amended complaint on November 6, 2021. Mayweather did not timely answer or otherwise respond. The company then moved for entry of a default judgment.
Personal Jurisdiction
Before entering a default judgment, a court must determine that it has personal jurisdiction, meaning legal authority over the defendant. The court explained that this inquiry requires both a statutory basis for jurisdiction and compliance with constitutional due-process limits. Due process generally requires sufficient minimum contacts between the defendant and the forum state, as well as a reasonable basis for requiring the defendant to litigate there.
The court held that the company had not pleaded enough facts to establish personal jurisdiction over Mayweather in New York. The amended complaint stated that Mayweather resided in Florida and that the transaction at issue occurred entirely in Florida. The company argued that Mayweather’s knowledge that he was dealing with a New York business established the necessary connection. The court rejected that argument because personal jurisdiction focuses on the defendant’s own contacts with New York, not merely the plaintiff’s connection to New York or the defendant’s contacts with a person or business located there.
Disposition
The court concluded that the company had not established that Mayweather was subject to personal jurisdiction in New York. Judge Mary Kay Vyskocil therefore DENIED the motion for entry of default judgment and DISMISSED without prejudice the action for lack of personal jurisdiction. The clerk was directed to terminate the motion and close the case. The opinion did not decide whether the company’s contract, quantum-meruit, or unjust-enrichment claims were substantively valid.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.