District Court Finds Personal Jurisdiction Over Quebec Corporation that Negotiated and Executed Contract with U.S. Company and Made Numerous Visits to Iowa Over Two Years

Relco Locomotives, Inc. v. AllRail, Inc., U.S. District Court, Southern District of Iowa March 5, 2014

Defendant AllRail, Inc., a Quebec railroad services company, moved to dismiss breach of contract claims brought by Relco Locomotives, an American company, with which AllRail had contracted to rebuild two locomotives, for lack of personal jurisdiction. Relco alleged that AllRail had failed to pay money due under their contract, while AllRail filed suit separately in Montreal relating to alleged defects in the repair of the locomotives.

The District Court in Iowa found that AllRail had established minimum contacts with Iowa collectively through several contacts, none of which on its own would have been sufficient to confer jurisdiction. Specifically, the court cited AllRail’s contract with the Iowa company and their two year relationship, AllRail’s multiple visits to Iowa during the duration of the contract, and the fact that AllRail also arranged and executed the delivery of the locomotives from Iowa to Quebec. All of these contacts related directly to the cause of action and so specific personal jurisdiction existed.

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