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Logistics Dynamics LLC v. Rood Logistics LLC

Long-Arm Jurisdiction Lacking, Offends Due Process; Claims Sound in Contract, No NY Injury

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DECISION & ORDER The plaintiff, Logistic Dynamics, LLC, successor by merger to Logistic Dynamics, Inc., (“LDI”), initially commenced this action against Rood Logistics LLC (“Rood”) in New York State Supreme Court, Erie County, on July 8, 2021. Docket Item 1-1. On September 28, 2021, Rood removed the case to this Court based on diversity of citizenship. Id.; see also 28 U.S.C. §§1441 and 1332. Docket Item 1. On October 5, 2021, Rood moved to dismiss, arguing that this Court did not have personal jurisdiction over Rood under New York C.P.L.R. §302(a), New York’s long-arm statute; Rood also argued that exercising jurisdiction would violate its right to due process under the Fourteenth Amendment. Docket Item 8. LDI opposed the motion to dismiss, arguing that Rood’s actions in Georgia caused injury to LDI in New York, satisfying the long-arm statute, and that Rood’s connection with New York satisfied any constitutional concerns. Docket Item 11. Rood replied on October 26, 2021. Docket Item 12. For the following reasons, Rood’s motion to dismiss for lack of personal jurisdiction is granted. BACKGROUND1 LDI, a Delaware company with its principal place of business in New York, Docket Item 1-1 at 1, is a transportation company with “a network of available trucks, drivers, and other logistic support information,” Docket Item 11-1 at

3-4. Rood, a Georgia company, Docket Item 1-1 at 2, is a transportation broker that links clients with transportation companies, Docket Item 11-1 at 4. In early 2015, LDI entered into a business arrangement with Rood. Docket Item 1-1 at 4. Under this arrangement, Rood performed freight brokerage services on behalf of LDI and its customers. Id. Rood used “LDI Freight,” a remote broker software program “housed, monitored, and maintained [by LDI] in New York State,” to enter the loads for shipment. Docket Item 11-1 at

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