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Phillips v. Prairie Eye Center

District court lacked specific personal jurisdiction over out-of-state medical practice sued by newly-hired physician after parties negotiated, but failed to perform, employment contract; medical practice did not subject itself to jurisdiction of physician's home state merely by mailing proposed contact there and following up on logistics with three e-mails, and purpose of agreement was physician's employment out of state.

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Before Lynch, Circuit Judge, Merritt, *fn1 Senior Circuit Judge, and Howard, Circuit Judge.

This dispute arises from an employment negotiation gone awry. Christopher Phillips, an ophthalmologist who lived at the time in Massachusetts, interviewed in Illinois for a job with Prairie Eye Center, a full service ophthalmology practice. After both parties signed an employment contract for Phillips to go work for Prairie Eye in Illinois, the relationship between the two deteriorated. Phillips never went to work for Prairie Eye.

He filed suit against Prairie Eye in Massachusetts state court asserting personal jurisdiction over the defendant pursuant to the Massachusetts long-arm statute, Mass. Gen. Laws ch. 223A, § 3. After Prairie Eye removed the case to federal court, the district court found that Prairie Eye lacked the requisite minimum contacts with Massachusetts and dismissed the case. We agree and affirm the dismissal.

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