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Passive Business Ownership Not Sufficient Grounds for Jurisdiction
Description French hotel company that owns large minority interest in U.S. motel chain could not be subject to jurisdiction in suit by motel employee against motel chain. The French company played no active role in managing the U.S. company, so it did not subject itself to personal jurisdiction.
Topic Court Procedure
Key Words Jurisdiction, Parent Company, Sufficient Contacts
C A S E   S U M M A R Y
Facts Lisa Dean worked at a Motel 6 in Richmond, Kentucky, where she was assaulted by a guest of the motel. She sued Motel 6 Operating and Accor, a French hotel company that owns 40 percent of Motel 6, for negligence in the management of the premises of the hotel. Accor moved to dismiss on the grounds that the court lacked personal jurisdiction. District court granted the dismissal. Dean appealed.
Court of Appeals Decision Affirmed. "There is no evidence in the record that Accor 'did business' in Kentucky, or took any affirmative actions relating to Kentucky beyond merely owning (with a minority interest) Motel 6 Operating." Proof of ownership is insufficient to show that Accor "purposefully availed" itself of activities in the forum state. The fact that Motel 6 directories asked travelers to "look up our European cousin," an Accor-owned chain, is suggestive of a business relationship, but not proof that Accor had any control over Motel 6 operations. Similarly, evidence that various executives of the two companies had previously worked for the other does not show "that Accor actually runs Motel 6."
Citation Dean v. Motel 6 Operating L.P., 134 F.3d 1269 (6th Cir., 1998)

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