District Judge Laura Taylor Swain
Michigan resident LeDuc is president of Michigan’s Thomas M. Cooley Law School (Cooley), which lacks any campus, offices, employees or agents in New York. Asserting breach of New York’s Anti-SLAPP law, New York law firm Kurzon sought damages for defamation and prima facie tort based on communications by LeDuc, on Cooley’s intranet, to Cooley students about MacDonald v. Thomas M. Cooley Law School—then-pending litigation in Michigan arising from a 2011 investigation by predecessor Kurzon Strauss lawyer Anziska into whether Cooley manipulated post-graduate salary information to attract students. Despite determining that it held subject matter jurisdiction under 28 USC §1332, district court granted Cooley and LeDuc dismissal of Kurzon’s lawsuit. Kurzon failed to demonstrate a proper basis for the court’s exercise of long-arm jurisdiction. Kurzon’s instant lawsuit was not based on Cooley’s alleged Internet advertisement scheme law school recruitment fair participation or externship programs. Even if Kurzon’s claim that Cooley engaged in false advertising in New York were true, it was insufficiently related to the specific allegations in its action against Cooley to support exercise of jurisdiction over defendants.