TLSL, Inc. v. Rankin Snead, as Administrator Ad Litem of the Estate of Juan Estrada, et al.

TLSL, Inc. (“TLSL”) is a Mississippi excavation contracting company. It is incorporated in Mississippi and has its principal place of business in Mississippi. Nevertheless, Alabama courts have determined TLSL is subject to general personal jurisdiction in Alabama. This is a clear violation of TLSL’s due process rights. This Court established the “at-home” test for general personal jurisdiction in Goodyear and Daimler and reaffirmed its application in Tyrrell. The question presented is whether this test should apply equally to more modest enterprises, such as TLSL, that only have connections with a minimal number of jurisdictions. The second question is whether TLSL’s due process rights were violated when Alabama’s courts held this is an “exceptional” case to subject TLSL to personal general jurisdiction despite it being incorporated in Mississippi and having its only place of business in Mississippi. More specifically, the question is whether TLSL’s operations in Alabama were so substantial and of such a nature as to render it “at home” in Alabama. This question would allow the Court to provide clarity to litigants and lower courts regarding this high burden.