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The Third Circuit Court of Appeals has affirmed the dismissal of an employee's slip and fall injury accident case against the Cabot Oil and Gas company, and the drilling outfit, Patterson UTI, where he worked. However, the lawsuit was not dismissed on summary judgment, nor via the all too familiar 12(b)(6), but rather via a 12(b)(2) jurisdictional challenge.
In short, both the district and appellate courts ruled that the court did not have sufficient jurisdiction over the defendants due to their lack of contact with the state of New Jersey, where the case was filed.
What's This All About?
The facts of the underlying case are rather simple. The plaintiff had an on-the-job slip and fall injury while working on an oil drilling platform covered in snow in Pennsylvania during the winter time. Although the injury happened in Pennsylvania, the case was filed in the Federal District Court in New Jersey.
Plaintiff attempted to argue that both oil and gas company, and the drilling company, had sufficient contacts with the state of New Jersey to render them subject to the state's general jurisdiction. However, neither company is headquartered in New Jersey, and none of the incidents giving rise to the incident happened in NJ.
The court explained that, in this case, even attempting to assert specific jurisdiction against either corporation fails. Neither corporation had the kind of substantial, or continuous and systemic contact with the state to render it "at home" in New Jersey. Furthermore, because the actual action leading to the injury did not occur in New Jersey, even if either company did have sufficient ties in the state, it could not be the basis of specific jurisdiction since the actions occurred in another jurisdiction.