District Court Grants Naval Equipment Manufacturer’s Motion to Dismiss for Lack of Personal Jurisdiction

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Jurisdiction: United States District Court for the District of Oregon

Plaintiffs Robert and Delores Thrasher sued 42 defendants alleging that Robert Thrasher’s asbestos exposure as a child in Oregon and in his Navy service led to his mesothelioma. They initially brought the action in Oregon state court; it was then removed to federal court.

Defendant Alfa Laval, incorporated in New Jersey with its principal place of business in Virginia, then moved for dismissal for lack of personal jurisdiction.

The court held that specific personal jurisdiction over Alfa Laval was lacking because the plaintiffs failed to show any meaningful connection between their claims and Alfa Laval’s activities in Oregon. Plaintiffs pleaded no specific facts that Alfa Laval manufactured, sold, or supplied asbestos‑containing products in Oregon, or that Robert Thrasher’s Navy service took him to Oregon. Alfa Laval’s current business activity in Oregon was minimal and not relevant to asbestos claims.

Plaintiffs also argued Alfa Laval knew its products would be installed on ships which would be likely to travel everywhere. The court rejected this argument, noting jurisdiction cannot be found merely due to unilateral action from third parties such as the Navy.

Because no other basis for federal jurisdiction remained, the district court remanded to Oregon state court.

A copy of the decision can be found here.

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