Roger Baskin v. Pierce & Allred Construction, Inc.

In this appeal, we address whether a Tennessee resident may sue an Alabama corporation in a Tennessee court for alleged breach of contract and breach of warranty pertaining to its construction of a custom lake house in Alabama. Tennessee resident Roger Baskin hired Pierce & Allred Construction, an Alabama corporation with its principal place of business in Alabama, to build a house on a parcel of land in Alabama. Mr. Baskin supplied the architectural plans and some of the materials, all sourced from Tennessee, and the parties communicated throughout the project from their respective states. However, all of Pierce & Allred Construction’s activities on the project occurred in Alabama. Mr. Baskin ultimately became dissatisfied with the quality and expense of the construction work, and he filed suit in the Davidson County Chancery Court. Pierce & Allred Construction moved to dismiss the complaint for lack of personal jurisdiction, arguing that the corporation lacked the “minimum contacts” with Tennessee that due process protections require. Int’l Shoe Co. v. Washington, 326 U.S. 310, 316 (1945). The trial court granted the motion, finding that the events relevant to the claims occurred in Alabama and that the corporation’s contacts with Tennessee were minor and attenuated. The Court of Appeals reversed, looking to recent decisions from this Court, see Crouch Ry. Consulting, LLC v. LS Energy Fabrication, LLC, 610 S.W.3d 460 (Tenn. 2020), and the United States Supreme Court, see Ford Motor Co. v. Mont. Eighth Jud. Dist. Ct., 141 S. Ct. 1017 (2021) (explaining that the exercise of specific personal jurisdiction requires that a plaintiff’s claim arise out of or relate to the defendant’s forum contacts). We granted permission to appeal. Based on our review, we have determined that Pierce & Allred Construction’s contacts with Tennessee were not such that the corporation reasonably should have anticipated being haled into a Tennessee court to answer this suit. In making this determination, we conclude that certain contacts with Tennessee did not reflect that the corporation purposefully availed itself of the privilege of conducting business activities in Tennessee, while certain other contacts were not sufficiently related to Mr. Baskin’s claims to support the exercise of specific personal jurisdiction. Thus, we hold that Mr. Baskin failed to establish a prima facie case of the minimum contacts necessary for a Tennessee court to exercise specific personal jurisdiction over the Alabama corporation. Accordingly, we reverse the decision of the Court of Appeals and reinstate the judgment of the trial court dismissing Mr. Baskin’s complaint.