Warfield v. W.N. Morehouse Truck Line, Inc. (Nov. 6, 2025)

Case details
Full caption
Jamison Warfield v. W.N. Morehouse Truck Line, Inc.
Country
United States
Jurisdiction
Federal
Decided
Nov. 6, 2025
Disposition
Dismissed
Majority
Clifton L. Corker (J.) (unanimous Court)
JAMISON WARFIELD, Plaintiff, v. W.N. MOREHOUSE TRUCK..., Slip Copy (2025) © 2025 Thomson Reuters. No claim to original U.S. Government Works.12025 WL 3102069Only the Westlaw citation is currently available.United States District Court, E.D.Tennessee, Northeastern Division,NORTHEASTERN DIVISION.JAMISON WARFIELD, Plaintiff,v.W.N. MOREHOUSE TRUCK LINE, INC., Defendant.2:25-cv-00037-DCLC-CRW|Filed 11/06/2025Attorneys and Law FirmsWilliam A. Wooten, Wooten Law Office, Covington, TN, forPlaintiff.C. Eric Stevens, Littler Mendelson, Nashville, TN, Ryan M.Kunhart, Pro Hac Vice, Dvorak Law Group, LLC, Omaha,NE, for Defendant.MEMORANDUM OPINION AND ORDERClifton L. Corker United States District Judge*1 Before the Court is Defendant's W.N. Morehouse TruckLine, Inc.'s (“Morehouse”) motion to dismiss [Doc. 7]Plaintiff Jamison Warfield's (“Warfield”) complaint [Doc.1] for lack of personal jurisdiction and improper venuepursuant to Federal Rules of Civil Procedure 12(b)(2) and (3).Warfield has responded [Doc. 14] to which Morehouse hasreplied [Doc. 15]. The matter is now ripe for adjudication.For the reasons stated, Warfield's complaint is DISMISSEDWITHOUT PREJUDICE.I. BACKGROUNDWarfield, an African-American individual, resides inTennessee, and Morehouse is a Nebraska corporation withits principal place of business in Omaha, Nebraska. [Doc.1, ¶¶ 1–2]. Warfield was employed by Morehouse fromOctober 3, 2023, until February 12, 2024, when Morefieldterminated his employment. Id. at 7. Warfield generallyasserts that Morehouse ended his employment as a result ofunlawful race-based discrimination. In support of this claim,Warfield alleges that during his employment, Morehouseassigned him fewer deliveries than his Caucasian coworkersand required him to remain on the lot between deliveries—requirements that were not imposed on similarly situatedCaucasian employees. Id. at ¶¶ 10–11. He also alleges thatMorehouse accused him of violating company policy for“going 10 miles off track to safely park the truck,” eventhough Caucasian employees who engaged in comparableconduct were not disciplined. Id. at 12. He contends hereported this discriminatory treatment, but Morehouse tookno corrective action. Id. at 13.On December 5, 2023, while making a delivery in Iowa,Warfield was informed that his next delivery would not beavailable until the following morning. Id. at 15. Due to thedelay, he drove to a truck stop to shower and eat. Id. Upon hisarrival, law enforcement arrested him on allegations that hehad stolen property from Morehouse. Id. at 16. The criminalcharges were later dismissed, but Morehouse terminated hisemployment. Id. at ¶¶ 18, 20–21. Warfield also alleges thatMorehouse confiscated his personal belongings, valued atabout $2,000.00, from his vehicle and failed to pay him hisfinal paycheck. Id. at ¶¶ 19–21. He asserts that Morehousethen replaced him with a Caucasian worker. Id. at 22.Based on these allegations, Warfield asserts claims for racialdiscrimination and retaliation in violation of Title VII of theCivil Rights Act, as well as claims under the Fair LaborStandards Act (“FLSA”) for Morehouse's alleged failure topay his final wages. Id. at ¶¶ 33–44. He seeks back pay,compensatory damages for emotional distress, and otherrelief. Id. at 45.Morehouse moves to dismiss the complaint for lack ofpersonal jurisdiction, arguing that as a Nebraska corporationwith its principal operations in Nebraska, it lacks sufficientcontacts with Tennessee to justify being hauled into courthere. [Doc. 8, pgs. 3–6]. It notes that it is not registered todo business in Tennessee, does not maintain operations inTennessee, and derives only a small portion of its businessfrom Tennessee clients. Id. It contends that Warfield's claimsdo not arise out of any Tennessee-related conduct and thatWarfield's residency alone cannot confer jurisdiction on thisCourt. Id. It argues that requiring it to litigate in Tennesseewould violate due process because its contacts with the stateare neither continuous nor systematic. Id.*2 Warfield opposes the motion, though his initial objectionconcerns Morehouse's misidentification of his first name as“James” instead of “Jamison.” [Doc. 14, pg. 1]. He argues thiserror reflects a lack of diligence and undermines Morehouse's
JAMISON WARFIELD, Plaintiff, v. W.N. MOREHOUSE TRUCK..., Slip Copy (2025) © 2025 Thomson Reuters. No claim to original U.S. Government Works.2jurisdictional analysis. Id. at pg. 2. But the Court will notaddress that point, as it does not relate to the merits of themotion. On the merits, Warfield argues that Morehouse'sbusiness activities in Tennessee, however limited, and itsdecision to hire and supervise him while he resided inTennessee, establish sufficient minimum contacts to supportjurisdiction. Id.In reply, Morehouse notes that Warfield relied on incorrectand nonexistent case citations. [Doc. 15, pgs. 1–2].Substantively, Morehouse argues that it did not purposefullyavail itself of conducting activities in Tennessee, assertingthat it merely hired a Tennessee resident through a generalFacebook job posting. Id. at pgs. 2–4. Morehouse contendsthat hiring a resident of Tennessee, without more, is notsufficient purposeful availment nor does it create a continuingobligation in Tennessee. Id. at pg. 3. Morehouse maintainsthat Warfield's residency is the only connection to Tennesseeand is not enough to establish personal jurisdiction. Id.II. LEGAL STANDARDMotions to dismiss under Rule 12(b)(2) involve a burdenshifting analysis. The plaintiff must first establish jurisdiction,which may be done through the complaint. Malone v. StanleyBlack & Decker, Inc., 965 F.3d 499, 504 (6th Cir. 2020)(citing Am. Greetings Corp. v. Cohn, 839 F.2d 1164, 1169(6th Cir. 1988)). “[I]n the face of a properly supportedmotion for dismissal, the plaintiff may not stand on hispleadings but must, by affidavit or otherwise, set forth specificfacts showing that the court has jurisdiction.” Theunissen v.Matthews, 935 F.2d 1454, 1458 (6th Cir. 1991).A district court has discretion in how it resolves a Rule 12(b)(2) motion to dismiss. Malone, 965 F.3d at 505. “If it decidesthat the motion can be ruled on before trial, the court maydetermine the motion on the basis of affidavits alone; or itmay permit discovery in aid of the motion; or it may conductan evidentiary hearing on the merits of the motion.” Serrasv. First Tennessee Bank Nat. Ass'n, 875 F.2d 1212, 1214 (6thCir. 1989) (citation omitted). The court's choice affects theplaintiff's burden. Id. If the court holds an evidentiary hearing,the plaintiff must establish jurisdiction by a preponderanceof the evidence. Id. But when the district court rules onwritten submissions alone, it “must consider the pleadingsand affidavits in the light most favorable to the plaintiff” andthe plaintiff's burden consists of “a prima facie showing thatpersonal jurisdiction exists.” Id. The district court may notconsider a defendant's affidavit included with its motion todismiss if it chooses to rule on written submissions alone. Id.In its motion to dismiss, Morehouse did not request anydiscovery in aid of its motion nor an evidentiary hearing.See [Docs. 7, 8, 15]. The Court declines to hold a pretrialevidentiary hearing and exercises its discretion to decidewhether Warfield has made a prima facie showing of personaljurisdiction based on the allegations in his pleadings andaffidavit alone. [Docs. 1, 14-1].III. ANALYSISWhen exercising diversity jurisdiction, a federal court mayassert personal jurisdiction over a nonresident defendant onlyif a court of the forum state could do the same. Carbonev. Kaal, 140 F.4th 805, 809 (6th Cir. 2025). The inquiryinvolves two steps: (1) the defendant must be subject toservice of process under the forum state's long-arm statute;and (2) the exercise of personal jurisdiction must be consistentwith the Due Process Clause. AMB Media, LLC v. OneMB,LLC, No. 23-5607, 2024 WL 2052151, at *2 (6th Cir.May 8, 2024) (citing Bridgeport Music, Inc. v. Still N theWater Publ'g, 327 F.3d 472, 477 (6th Cir. 2003)). BecauseTennessee's long-arm statute reaches as far as federal dueprocess allows, the Court's analysis turns solely to whetherexercising personal jurisdiction over Morehouse satisfiesconstitutional requirements. Id.; see Tenn. Code Ann. §20-2-225; Gordon v. Greenview Hosp., Inc., 300 S.W.3d 635,646 (Tenn. 2009).*3 The Due Process Clause of the Fourteenth Amendmentprohibits any State from depriving a “person of life, liberty,or property without due process of law.” U.S. Const. amend.XIV, § 1. Consistent with that protection, a court may exercisepersonal jurisdiction over an out-of-state defendant onlywhen that defendant has “certain minimum contacts” withthe forum state such that maintaining the suit “does notoffend traditional notions of fair play and substantial justice.’” Carbone, 140 F.4th at 809–10 (quoting Int'l Shoe Co. v.Washington, 326 U.S. 310, 316 (1945)).Personal jurisdiction is either general or specific. Id. at 810.General jurisdiction exists only when a defendant's contactswith the forum state are “so continuous and systematic” thatthe defendant is essentially “at home there.” Id. (citationomitted). Warfield does not argue this Court has generaljurisdiction over Morehouse. The Court then considerswhether specific jurisdiction exists. Specific jurisdictionapplies where the plaintiff's claims “arise[ ] out of or relate[ ]to the defendant's contacts with the forum.” Id. (quotingDaimler AG v. Bauman, 571 U.S. 117, 127 (2014)). To
JAMISON WARFIELD, Plaintiff, v. W.N. MOREHOUSE TRUCK..., Slip Copy (2025) © 2025 Thomson Reuters. No claim to original U.S. Government Works.3establish specific jurisdiction, the plaintiff must show a “‘substantial connection’ among ‘the defendant, the forum,and the litigation.’ ” Id. (quoting Walden v. Fiore, 571U.S. 277, 284 (2014)). The concern “under either type ofjurisdiction ‘is the burden on the defendant.’ ” Id. (quotingBristol-Myers Squibb Co. v. Super. Ct. of Cal., S.F. Cnty., 582U.S. 255, 263 (2017)).The Sixth Circuit has established a three-part test for specificjurisdiction, commonly referred to as the Mohasco test. Id.(citing S. Mach. Co. v. Mohasco Indus., Inc., 401 F.2d 374,381 (6th Cir. 1968)). Under that test, exercising personaljurisdiction satisfies due process only if: (1) the defendantpurposefully availed itself of “the privilege of acting, orcausing a consequence” in, the forum state; (2) the plaintiff'sclaims arise from the defendant's forum-related activities;and (3) the defendant's conduct has “a substantial enoughconnection” with the forum state to make the exercise ofjurisdiction reasonable. Id. Each element is essential; if anyone of the three is not met, specific jurisdiction does not exist.LAK, Inc. v. Deer Creek Enters., 885 F.2d 1293, 1303 (6thCir. 1989).A. Whether Morehouse purposeful availed itself of theprivilege of conducting business in TennesseeThe first criterion focuses on whether Morehousepurposefully availed itself of the privilege of conductingbusiness in Tennessee. Morehouse claims it has not becauseonly a small portion of its business comes from Tennessee.But the Sixth Circuit has made clear that purposeful availmentdoes not turn on the percentage of a defendant's businessin the forum state. Neogen Corp. v. Neo Gen Screening,Inc., 282 F.3d 883, 891–92 (6th Cir. 2002). Instead, theinquiry is whether the defendant's contacts amount to morethan “random, fortuitous, or attenuated contacts with thestate.” Id. (quotations omitted). When “a defendant createsrepeated contacts through a regular course of business, it haspurposefully availed itself of that forum's jurisdiction.” AMBMedia, LLC, 2024 WL 2052151, at *6; see AlixPartners, LLPv. Brewington, 836 F.3d 543, 550 (6th Cir. 2016) (holdingthat a nonresident satisfies purposeful availment when itdeliberately engages in “significant activities” in the forum orcreates “continuing obligations” with the forum's residents)(quoting Burger King Corp. v. Rudzewicz, 471 U.S. 462, 475–76 (1985)).*4 Morehouse purposefully availed itself of the privilege ofconducting business in Tennessee. It hired Warfield knowinghe resided in Tennessee and assigned him a truck to use whileworking from his home base in Tennessee. [Doc. 1, 7; Doc.14-1, ¶¶ 4–8, 19–20]. It also arranged for Warfield to completehis DOT drug screening near his home in Morristown,Tennessee. [Doc. 14-1, ¶¶ 5–6]. Morehouse conducts businessby hauling loads into and out of Tennessee.1 [Doc. 1, 7;Doc. 14-1, 9]. Morehouse's revenue from brokered hauloperations into and out of Tennessee occurred in its regularbusiness, creating “continuing obligations between [itself]and residents of the forum.” AlixPartners, LLP, 836 F.3d at550. On this record, Warfield has made a prima facie showingthat Morehouse purposefully availed itself of the privilege ofconducting business in Tennessee.B. Whether Warfield's claims arise out of or relate toMorehouse's contacts with TennesseeThe second criterion is whether Warfield's claims “arise outof or relate to” Morehouse's contacts with Tennessee. Sullivanv. LG Chem, Ltd., 79 F.4th 651, 671 (6th Cir. 2023) (quotingFord Motor Co. v. Mont. Eighth Jud. Dist. Ct., 592 U.S.351, 359 (2021)). They do not. To satisfy this requirement,Morehouse's contacts with Tennessee must be “related to theoperative facts of the controversy.” MAG IAS Holdings, Inc.v. Schmuckle, 854 F.3d 894, 903 (6th Cir. 2017) (quotingBird v. Parsons, 289 F.3d 865, 875 (6th Cir. 2002)). Althoughthe Supreme Court has rejected a strict “causation-only”approach,2 it also emphasized that the “relate to” standardmust nevertheless “adequately protect defendants foreign toa forum.” Ford, 592 U.S. at 362.Warfield alleges that Morehouse discriminated and retaliatedagainst him by wrongfully terminating him and havinghim falsely arrested because of his race in violation ofTitle VII of the Civil Rights Act and that it failed to payhim wages owed under the FLSA. [Doc. 1, ¶¶ 33–44].These claims, however, arise from and relate to events thatoccurred outside of Tennessee. Morehouse's employmentdecisions were made in Nebraska, where it is incorporatedand maintains its principal place of business. Id. at 2.The alleged discriminatory conduct, including Morehouse'sdecision to terminate Warfield and the events leading tohis arrest, took place outside of Tennessee. Morehouse'stermination of Warfield, whether lawful or not, is unrelated toits business of transporting freight into and out of Tennessee.Thus, the termination decision did not “arise out of or relateto” Morehouse's contacts with Tennessee. Sullivan, 79 F.4that 671.
JAMISON WARFIELD, Plaintiff, v. W.N. MOREHOUSE TRUCK..., Slip Copy (2025) © 2025 Thomson Reuters. No claim to original U.S. Government Works.4To be sure, some courts have exercised personal jurisdictionover out-of-state employers in discrimination suits broughtby remote employees working in the forum state. But inthose cases, the courts exercised personal jurisdiction becausethe alleged discrimination occurred while the employeewas working in the forum state, or because the employerintentionally hired the employee to conduct business inthat state. See, e.g., Helferich v. GlyMed Plus, L.L.C., No.25-10194, 2025 WL 1572337, at *8 (E.D. Mich. June 3, 2025)(finding jurisdiction where defendant employed plaintiff toconduct business in the forum state and much of the allegeddiscrimination occurred there); Gronski v. InContact, Inc.,774 F. Supp. 3d 873, 886 (E.D. Mich. 2025) (same whereremote supervision in the forum state gave rise to the claim);McGechie v. Atomos Ltd., No. 2:22-CV-01812-DJC-DB,2024 WL 1054924, at *6 (E.D. Cal. Mar. 11, 2024) (holdingthat discriminatory acts, even done remotely, can establishjurisdiction). By contrast, none of the discriminatory orretaliatory conduct Warfield alleges occurred in Tennessee.3*5 Similarly, courts have declined to exercise personaljurisdiction where an employee's claims against an out-of-state employer arose from conduct occurring outside theforum state. See Fields v. Sickle Cell Disease Ass'n of Am.,Inc., 376 F. Supp. 3d 647, 652 (E.D.N.C. 2018), aff'd, 770F. App'x 77 (4th Cir. 2019) (finding no specific jurisdictionwhere the alleged discriminatory acts – such as disparagingremarks and work orders – occurred at business conferencesand business trips in other states). Likewise, in Clarke v.Tango Networks, Inc., the court held that the plaintiff's claimsdid not arise from the defendant's contacts with the forumstate because the relevant events took place in Chicago andduring work trips in Canada and Texas. No. 2:21-CV-00546,2021 WL 6095328, at *8 (S.D.W. Va. Dec. 23, 2021).And while the court in Helferich exercised jurisdiction, itdid so because the alleged discriminatory conduct occurredwhile the plaintiff was working in the forum state; the courtexpressly noted that the analysis would differ if all the allegedmisconduct had happened elsewhere. Helferich, 2025 WL1572337, at *9.Although Warfield resides in Tennessee and therefore mayexperience the effects of his alleged injuries here, the locationwhere he feels those injuries is not determinative. “[T]helocus of such a monetary injury is immaterial, as long asthe obligation did not arise from a privilege the defendantexercised in [the forum state].” LAK, 885 F.2d at 1302–03(citations omitted). The Supreme Court has emphasized thatthe defendant's own conduct must create the connection tothe forum. Walden, 571 U.S. at 284 (“[T]he relationship mustarise out of contacts that the defendant himself creates withthe forum State.”) (quotations omitted) (emphasis in original).Here, Warfield does not allege that the discriminatory orretaliatory actions he challenges occurred while his wasin Tennessee nor does he allege that Morehouse hiredhim for work specifically involving Tennessee deliveries.Warfield's residency alone “cannot be the only link betweenthe defendant and the forum.” Walden, 571 U.S. at 285; seealso Bulso v. O'Shea, 730 F. App'x 347, 351 (6th Cir. 2018)(holding that where all the facts occurred outside the forum,the claim did not arise from the defendant's contacts withthe state). So too here, because all the conduct underlyingWarfield's claims occurred outside of Tennessee, the claimsdo not arise out of or relate to Morehouse's contacts withTennessee, and specific jurisdiction is lacking.IV. CONCLUSIONIn sum, although Morehouse has some business contactswith Tennessee sufficient to establish purposeful availment,Warfield's claims do not arise out of or relate to thosecontacts. Because the second element of the Mohasco testis not satisfied, this Court lacks specific jurisdiction overMorehouse. And where either the purposeful availment or“arise out of or relate to” requirement is not met, the Courtneed not reach the third, reasonableness inquiry. See LAK,885 F.2d at 1303. Accordingly, the Court lacks personaljurisdiction over Morehouse, and the Complaint must beDISMISSED WITHOUT PREJUDICE.A separate Judgment follows.SO ORDERED:All CitationsSlip Copy, 2025 WL 3102069
JAMISON WARFIELD, Plaintiff, v. W.N. MOREHOUSE TRUCK..., Slip Copy (2025) © 2025 Thomson Reuters. No claim to original U.S. Government Works.5Footnotes1Morehouse contends that it should not be subject to personal jurisdiction because it does not conduct asubstantial amount of business in Tennessee. [Doc. 8, pgs. 3–4]. Without conducting an evidentiary hearing,however, the Court may only consider whether Warfield has made a prima facie showing of personaljurisdiction based on the factual allegations asserted by Warfield in his complaint [Doc. 1] and affidavit inresponse to the motion to dismiss [Doc. 14-1].2In Ford, the Supreme Court rejected the argument that jurisdiction exists only where the “defendant's forumconduct gave rise to the plaintiff's claims.” Ford, 592 U.S. at 361.3Warfield alleges that in November 2023, while in Louisiana, Morehouse refused to pay him for approximatelyone week while he remained in a hotel waiting for repairs to his assigned truck. [Doc. 14-1, 10]. He furtheralleges that the events leading to his termination occurred in Iowa on or about December 5, 2023. [Doc. 1, ¶¶15–19; Doc. 14-1, ¶¶ 11–18]. According to Warfield, after delivering a load in Iowa, he drove to a nearby truckstop to shower and eat when no additional loads were assigned to him. He claims that, while there, he wasarrested, detained overnight, and charged with theft “based on his employer's call to the authorities.” [Doc.1, 16].End of Document© 2025 Thomson Reuters. No claim to original U.S. Government Works.
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