Reported / Citable
Background
Jurnee Scott Leyman sued Amazon entities, an Ohio trucking company, and several trucking-company agents after a June 2023 crash on U.S. 287 in Potter County, Texas. Leyman alleged that a truck operated by Timur Trucking drivers, while hauling an Amazon-branded trailer on an Amazon delivery assignment, traveled the wrong way on a divided highway, killing her husband Noah Leyman and injuring her.
The suit was filed in the Southern District of Ohio. Amazon moved to dismiss for lack of personal jurisdiction or, alternatively, forum non conveniens. Leyman argued that Amazon’s Ohio business activities and its contractual relationship with Ohio-based Timur Trucking supported jurisdiction; she requested transfer to the Northern District of Texas if jurisdiction was lacking.
The Court’s Holding
Judge Susan J. Dlott held that the court lacked personal jurisdiction over the Amazon defendants. Although Amazon purposefully availed itself of Ohio by conducting business there and contracting with an Ohio trucking company, Leyman’s Texas tort claims did not arise from or sufficiently relate to Amazon’s Ohio contacts. The Ohio contract and Relay-app access were too attenuated from the New Mexico-to-Texas shipment and the Texas collision.
The court also held that Ohio’s long-arm statute was not satisfied because Amazon’s Ohio-related conduct was not the proximate cause of the crash. It denied jurisdictional discovery because Leyman identified no disputed, material jurisdictional facts. Rather than dismiss Amazon, however, the court transferred the entire action to the Northern District of Texas under 28 U.S.C. § 1404(a), so all claims could proceed in one forum closer to the accident, witnesses, and evidence.
Key Takeaways
- An Ohio trucking company’s acceptance of an Amazon load through an online platform did not create specific jurisdiction in Ohio over Amazon for a Texas crash.
- Amazon’s general Ohio operations and contractual dealings with the Ohio carrier were insufficiently connected to the out-of-state accident.
- Transfer, rather than dismissal, served the interests of justice because Texas was the location of the fatal collision and relevant evidence.
Why It Matters
The decision underscores that a national company’s business presence in a state does not alone permit suit there for an accident occurring elsewhere. For specific jurisdiction, the defendant’s forum contacts must have a substantial connection to the particular controversy.
It also illustrates a practical use of venue transfer where personal jurisdiction fails as to some defendants but a single transferee forum can adjudicate the full dispute.