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Southern District of Illinois - No Personal Jurisdiction in Illinois Over Multiple Defendants (Feb. 19, 2015) February 27, 2015

In five separate, but virtually identical decisions, the district court for the Southern District of Illinois granted the motions to dismiss of five defendants under Illinois’ long arm statute for lack of personal jurisdiction. After recognizing that Illinois’ long arm statute is as broad as is constitutionally permissible, it concluded in each case that the defendant did not have continuous and systematic contact as to make Illinois their home. Even though each defendant had some connection with Illinois, the court nevertheless found there was no personal jurisdiction.

For example, with respect to Exxon, the court stated: “Here, Plaintiff does not contend that Exxon is incorporated in or maintains a principal place of business in Illinois. Further, Plaintiff has provided no facts that would indicate that Exxon's affiliation with Illinois is ‘so continuous and systematic as to render’ it at home in Illinois. Plaintiff merely asserts that discovery will indicate that Exxon has a presence in Illinois including a refinery. The Supreme Court, however, has made it clear that the mere presence of a defendant in the forum does not subject it to all-purpose jurisdiction in that forum. See Daimler AG, 134 S. Ct. at 752, 762 (finding no general jurisdiction over a foreign corporation where a subsidiary, whose actions were assumed attributable to the corporation, had multiple facilities and a regional office in the forum state). Accordingly, Plaintiff has failed to make out a prima facie case of personal jurisdiction.”

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