Court: Court of Appeals for the Seventh Circuit; March 13, 2014; Federal Appellate Court
Ann Snodgrass, a former employee of Berklee College of Music, Massachusetts Institute of Technology, and Boston University, filed a lawsuit in the Northern District of Illinois claiming wrongful termination due to sex discrimination under 42 U.S.C. § 2000e-2(a)(1). The district court dismissed her case without prejudice, ruling that Illinois lacked personal jurisdiction over the defendants. The institutions, all based in Massachusetts, provided affidavits indicating minimal connections to Illinois: Berklee has no direct income from the state, MIT has no instructors based there despite offering online courses, and Boston University has a small percentage of Illinois students. Snodgrass did not contest this data. She argued on appeal that general personal jurisdiction exists because the institutions have substantial endowments and extensive online presence. Additionally, she requested a reconsideration of the precedent set in Helicopteros Nacionales de Colombia, S.A. v. Hall, suggesting that dissenting opinions may provide valuable insights. The appeal focuses on whether Snodgrass demonstrated sufficient contacts to establish general jurisdiction, noting that general jurisdiction applies when a corporation's affiliations with a state are continuous and systematic. The complexities of personal jurisdiction concerning Internet contacts were acknowledged, referencing previous case law.
Limited online interactions between Berklee College, MIT, and BU with Illinois do not establish general personal jurisdiction in the state, as supported by the Supreme Court's ruling in Daimler AG. The defendants’ connections to Illinois are less substantial than those in Gehling v. St. George’s Sch. of Med. Ltd., where a Pennsylvania university had significant ties to the state, including a notable percentage of Pennsylvania students and media presence. Other cases, such as uBID, Hemi Group, and CollegeSource, illustrate that mere online engagement does not suffice for general jurisdiction, even when companies earn revenue from state residents. Snodgrass's claim that the defendants have substantial online student interactions lacks evidentiary support and is deemed irrelevant. The responsibility to prove jurisdiction lies with Snodgrass, and no additional evidence of the defendants' contacts with Illinois was presented. The court emphasizes adherence to Supreme Court precedent, indicating that even if reassessment of Helicopteros were possible, Snodgrass would still not meet the required threshold for general jurisdiction, leading to the affirmation of the lower court's decision.
