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Henneberger v. Ticom Geomatics, Inc.

Citation: 602 F. App'x 352Docket: No. 14-3685

Court: Court of Appeals for the Seventh Circuit; May 11, 2015; Federal Appellate Court

Narrative Opinion Summary

In this case, the appellant challenged the dismissal of his breach-of-contract suit for lack of personal jurisdiction. The appellant asserted claims against a company and its affiliates, alleging they failed to fulfill a promise relating to equity or sale proceeds. The defendants, having removed the case to federal court, moved to dismiss based on insufficient contacts with Illinois. They supported their motion with affidavits and documents purportedly signed by the appellant. The appellant argued that the defendants' ties to Illinois were substantial due to past ownership by a Chicago-based firm. Additionally, he sought sanctions under Federal Rule of Civil Procedure 11, alleging forgery of his signature. The district court dismissed the action, citing the appellant's failure to establish a prima facie case for personal jurisdiction and denied the sanctions motion as moot. On appeal, the court upheld the dismissal, also denying the appellant's request to introduce new evidence, emphasizing procedural constraints. The outcome underscores the necessity of demonstrating sufficient minimum contacts to establish personal jurisdiction under Illinois law, and the adherence to procedural rules in appellate review.

Legal Issues Addressed

Federal Rule of Civil Procedure 11 Sanctions

Application: The plaintiff's motion for sanctions was denied due to the dismissal of the case for lack of personal jurisdiction, rendering the motion moot.

Reasoning: The court also denied his sanctions motion as moot.

Introduction of New Evidence on Appeal

Application: The appellate court declined to consider new evidence not presented at the district court level, adhering to procedural rules.

Reasoning: Henneberger's subsequent request to introduce new evidence on appeal was denied, as the court does not consider evidence not presented at the district court level.

Personal Jurisdiction Requirements under Illinois Law

Application: The court found that the plaintiff did not demonstrate sufficient minimum contacts by the defendants with Illinois to establish personal jurisdiction.

Reasoning: The district court dismissed Henneberger's case, finding he failed to establish a prima facie case for personal jurisdiction, as his claims lacked supporting evidence against the defendants' affidavits.