ILLINOIS – John Crane filed separate lawsuits against two plaintiffs’ law firms, Shein Law Center and Simon Greenstone Panatier Bartlett, alleging fraud, conspiracy and violations of the RICO Act related to asbestos lawsuits filed by the firms against John Crane. Shein Law Center is based in Pennsylvania, while Simon Greenstone is based in Texas. John Crane is an Illinois resident. John Crane filed suit against the firms in the Northern District of Illinois. The district court dismissed both matters due to a lack of personal jurisdiction over the defendants, and the cases were consolidated for appeal.
John Crane argued that the court had personal jurisdiction over the defendants – even though the allegedly fraudulent litigation transpired in California, Texas and Pennsylvania – because discovery and other materials were served on John Crane in Illinois. The court disagreed, finding such materials were incidental to the litigation and insufficient to establish personal jurisdiction.
The Seventh Circuit upheld the dismissals, concluding that out-of-state litigation against an Illinois resident is not sufficient to establish personal jurisdiction in Illinois over a lawyer involved in the out-of-state litigation. Of note, the court did comment that its opinion did not go to the merits of John Crane’s allegations.