Ostrem v. PrideCo Secure Loan Fund, LP

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Plaintiff formed a contract with Imperial Premium Finance with regard to a financing arrangement for life insurance. Imperial later assigned its interest in the arrangement to Defendant, a limited partnership with its principal place of business in California. Plaintiff filed a petition for declaratory judgment in Iowa, claiming that the contract was not valid. The district court granted Defendant’s motion to dismiss for lack of personal jurisdiction, concluding that that contacts of Imperial, the assignor, did not impute to Defendant, the assignee. The Supreme Court reversed, holding (1) an assignor’s contacts with Iowa are not automatically imputed to the assignee for purposes of obtaining personal jurisdiction over the assignee, but this assignee is subject to personal jurisdiction in Iowa based on its own contacts with this forum through the contractual relationships it assumed by the assignment; and (2) Defendant in this case did have the required minimum contacts to subject Defendant to personal jurisdiction in Iowa. Remanded. View "Ostrem v. PrideCo Secure Loan Fund, LP" on Justia Law