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Keaty LLC v. Blueprint Summer Programs, Inc., 2020 UT App 9 (Jan. 9, 2020)

Jan 9, 2020

On appeal from the lower court’s dismissal for lack of personal jurisdiction, the court of appeals held that the district court properly concluded that it lacked personal jurisdiction over a North Carolina corporation, Blueprint.  The plaintiffs, including a consulting company headquartered in Nevada and Utah, asserted that the court could exercise specific personal jurisdiction over Blueprint because Blueprint allegedly enticed a Utah-based employee away from a Utah-based company in violation of the parties’ contract.  The court disagreed, holding that, under Walden v. Fiore, 571 U.S. 277 (2014), grounding personal jurisdiction over Blueprint based upon the plaintiffs’ connections to Utah would “impermissibly allow[] a plaintiff’s contacts with the defendant and the forum to drive the jurisdictional analysis.”  Although the court could “imagine specific acts directed at Utah that Blueprint might have taken to recruit the employee,” the plaintiff failed to make any such allegations.