Ciabattoni v. Teamsters Local 326

Citation: Not availableDocket: N15C-04-059 VLM

Court: Superior Court of Delaware; February 11, 2020; Delaware; State Appellate Court

Original Court Document: View Document

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The Superior Court of Delaware issued a decision regarding Plaintiff Michael Ciabattoni's Motion to Amend his Complaint to include Christopher Buschmeier and Michael Thiemer as Defendants in the case Ciabattoni v. Teamsters Local 326. The Court granted the motion in part and denied it in part. Specifically, the Court allowed the Plaintiff to amend certain language in the Second Amended Complaint, correcting the term “spouse” to “significant other” and clarifying the nature of business dealings with FedEx. However, the Court denied the addition of Buschmeier and Thiemer as Defendants, with the Plaintiff arguing that Buschmeier is subject to personal jurisdiction due to significant business contacts in Delaware and a conspiracy theory jurisdiction rationale. The Court noted the procedural history, including previous rulings on related motions and the oral arguments presented by both parties on November 5, 2019. The decision reflects careful consideration of the Plaintiff's requests and the Defendants' opposition.

Plaintiff seeks an order to amend the complaint and add defendants, arguing that Thiemer is subject to personal jurisdiction through "conspiracy theory jurisdiction" and that the new allegations relate back to the original complaint's filing date. Plaintiff asserts that the proposed defendants are necessary parties for complete relief. Defendants counter that the amendment is a futile attempt to salvage the case, would not withstand a motion to dismiss under Rule 12(b)(6), and would cause undue delays and prejudice. They also claim the proposed claims are barred by the Statute of Limitations. Non-party Buschmeier contends the court lacks jurisdiction over him as an out-of-state resident and argues that Plaintiff has not sufficiently alleged notice or mistake as required by Rule 15(c).

The Court outlines the standard for amending pleadings under Delaware Superior Court Civil Rule 15(a), emphasizing that amendments should be freely granted unless they cause undue prejudice, involve bad faith, or other significant issues. The burden is on Plaintiff to establish jurisdiction over the proposed defendants through a two-step analysis: first, under Delaware's long-arm statute, and second, whether the jurisdiction aligns with federal constitutional standards. The Court notes that it will not consider the constitutional aspect if Plaintiff fails to demonstrate jurisdiction under the long-arm statute.

Delaware law allows for general jurisdiction when a non-resident has substantial contacts with the state, regardless of claim relevance, or specific jurisdiction when there is a direct link between the cause of action and the defendant's conduct. Plaintiff argues that Buschmeier has significant contacts with Delaware as an officer of Local 107 of the Teamsters and claims he directed actions related to this litigation from Pennsylvania, alleging close ties with the Individual Teamster Defendants.

In Sokol Holdings, Inc. v. Dorsey, Whitney, LLP, the Superior Court denied a motion to amend a complaint to add defendants, ruling the amendment was futile due to lack of personal jurisdiction over the proposed defendants, Christopher Buschmeier and Michael Thiemer. The Court found that the plaintiffs did not demonstrate that Buschmeier engaged in regular or persistent conduct in Delaware or derived substantial revenue from services there. The plaintiffs argued significant contacts through Buschmeier's personal relationship with Defendant Smith, but the Court clarified that a defendant must be present during the tortious conduct for jurisdiction to apply. 

In a related case, Rotblut v. Terrapinn, Inc., the Court concluded that mere knowledge that a website could be viewed in Delaware was insufficient for jurisdiction, as the defendant did not purposefully target Delaware residents. Similarly, the plaintiffs failed to show that Buschmeier’s online actions connected him to Delaware in a way that established jurisdiction. 

Regarding Thiemer, who was alleged to be involved with the Teamsters campaign and an administrator of a relevant Facebook page, the plaintiffs argued he acted in Delaware. However, he was identified as a New Jersey resident, and the Court found no evidence that his actions constituted sufficient contact with Delaware. The plaintiffs' reliance on a "conspiracy theory jurisdiction" was also rejected, consistent with previous rulings by the Court. Ultimately, the Court ruled that the proposed amendment to include Buschmeier and Thiemer as defendants would not withstand inevitable motions to dismiss for lack of jurisdiction. The motion was partially granted to correct language but denied in terms of adding the defendants. Judge Vivian L. Medinilla issued the ruling.