In re Roman Catholic Diocese of Albany, N.Y., Inc.
This petition for writ of mandamus addressed the purported lack of personal jurisdiction that the District of Vermont had over Defendant-Petitioner, the Roman Catholic Diocese of Albany, N.Y. (“Diocese”). The district court found that it had general jurisdiction over the Diocese because it was deemed to be at home in Vermont. Subsequently, the Diocese sought the writ to compel the district court to dismiss the case for lack of personal jurisdiction.
The Respondent-Plaintiff, Michael Shovah, brought suit in district court alleging that one of the Diocese’s priests had transported him as a minor from New York to Vermont in order to sexually abuse him. The district court found that it maintained general jurisdiction over the Diocese even though the church is a New York special act corporation covering fourteen counties in New York with its principle office in Albany. Furthermore, the district court maintained the Diocese was at home in Vermont even though it owned no real property, did not maintain an office, and did not have any financial accounts in the state.
The Diocese moved to dismiss for want of personal jurisdiction, but the district court held that the priest’s weekly masses and sixteen services conducted by other priests over a ten-year period were continuous and systematic enough to render Vermont as the Diocese’s home. The court thereafter denied the motion for an interlocutory appeal and allowed the case to move forward, as the Diocese was directed to produce documents dating back from 1975 reflecting sexual abuse allegations. The Diocese subsequently filed this writ of mandamus and requested expedited consideration from the Second Circuit.
The Second Circuit ultimately granted the Diocese’s petition for writ of mandamus, compelling the district court to dismiss the case against it for lack of personal jurisdiction. In recognizing the nature of the special circumstances and remedy surrounding a writ of mandamus, the Second Circuit found that the district court erroneously exercised personal jurisdiction over the Diocese and that issuing the writ of mandamus was the appropriate remedy.
The Second Circuit reasoned that mandamus was the only correct means of relief because a post-trial appeal would have done nothing to prevent harm that the Diocese would endure by divulging its employee records and, furthermore, such sexual abuse litigation would have been time-barred if brought in the Diocese’s true home state of New York.
Additionally, the mandamus was deemed appropriate given the circumstances inasmuch as the district court’s personal jurisdiction analysis was patently erroneous due to the Diocese’s attenuated affiliation with Vermont. Thus, it was not essentially at home in the state to have general jurisdiction asserted over it. The Second Circuit noted that it needed to issue guidance regarding the proper general personal jurisdiction because the district court misapplied the law.
Finally, the Second Circuit held that the Diocese had a clear and indisputable right to the writ because the district court abused its discretion by patently applying an erroneous view of personal jurisdiction law. Having eighteen Vermont-resident employees over ten years, twenty-one Vermont based vendors over ten years, and 0.08% of its donations coming from Vermont did not constitute the minimum contacts necessary to be “at home” for general jurisdiction purposes. In the face of legal precedence, the Second Circuit articulated that in no way did the Diocese have the systematic and continuous contact with Vermont necessary for the district court to assert general jurisdiction.
Accordingly, the Second Circuit directed the lower court to dismiss the case against the Diocese because Vermont could not exert personal jurisdiction upon it.
2014 WL 485948 (2d Cir. 2014)