Frank Cruz-Alvarez is a Partner in the Miami, FL office of Shook, Hardy & Bacon L.L.P., and Ashley Hayes is an Associate with  Shook, Hardy & Bacon L.L.P. in its Tampa, FL office. Mr. Cruz-Alvarez is the WLF Legal Pulse’s Featured Expert Contributor on Civil Justice/Class Actions.

In a recent decision, the Fourth Circuit affirmed the trial court’s dismissal of a cause of action against Marriott International Inc., holding that the defendant was not subject to personal jurisdiction in South Carolina because it did not own any hotels or otherwise have any significant business in South Carolina, and the actions giving rise to the dispute did not occur in South Carolina.  Fidrych v. Marriott International, Inc., 952 F.3d 124 (4th Cir. 2020).   Specifically, the Fourth Circuit affirmed the lower court’s decision that Marriott’s business contacts with South Carolina were insufficient to render it “at home” in the state to establish general personal jurisdiction, and its case-related contacts were not substantial enough to satisfy the requirements for specific personal jurisdiction.  Id. at 147.