MGM Grand, Inc. v. Eighth Judicial District Court

Mowbray, C. J.,

dissenting:

Respectfully, I dissent.

Questions of personal jurisdiction over a non-resident defendant are decided under the “minimum contacts” analysis.1 See Hanson v. Denckla, 357 U.S. 235 (1958); McGee v. International Life Ins. Co., 355 U.S. 220 (1957); International Shoe Co. v. Washington, 326 U.S. 310 (1945). Under Nevada law “two principal factors must be considered in determining whether a court may constitutionally exercise personal jurisdiction over a given corporate defendant: the significance of the defendant’s contacts with the forum and the relationship of the cause of action to those forum contacts.” Wells Fargo & Co. v. Wells Fargo Exp. Co., 556 F.2d 406, 412-413 (9th Cir. 1977).

Disney’s preliminary contact with Nevada is a contract. See *71Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985) (a contract can be a contact).2 The contract at issue grants Disney the “worldwide exclusive right” to use the “MGM” name, logos, trademarks, and films in connection with studio theme parks. This contract, if valid, gives Disney the right to oust MGM Grand from using the “MGM” name in Nevada. While this “worldwide” contact might seem somewhat intangible, it is certainly significant when one considers the size of the project at issue. Moreover, this contact is directly related to the declaratory judgment action. (One significant fact is that the contract contained a “choice of law” clause, but not a “choice of forum” clause. This suggests that Disney anticipated being haled into court in other jurisdictions where a controversy might arise.)

Disney’s contacts with Nevada extend beyond the existence of the above contract. Disney has “purposefully directed” its activities towards Nevada by taking the position that MGM’s planned theme park is inconsistent with Disney’s contract.3

MGM’s complaint alleges that “Disney seeks to prevent the plaintiffs from using the ‘MGM Grand’ name with respect to the construction and operation of competitive enterprises which would employ many people and generate substantial revenues in the State of Nevada, particularly in the City of Las Vegas.” It further alleges that, “when advised that the building and operation of an amusement park in Las Vegas was under consideration and when plaintiffs’ representatives expressed their plan to use the aforementioned marks, Disney flatly disputed and denied the right to use said marks in any such connection.”

Disney essentially concedes MGM’s allegation. In a motion to quash service of process, Disney states: “Plaintiffs, who claim to have a plan to construct a movie theme park and studio tour, know full-well that any such plan would be in complete derogation of Disney’s rights.”

Jurisdiction is established when plaintiffs present facts which make a prima facie showing of personal jurisdiction. Davis v. District Court, 97 Nev. 332, 337, 629 P.2d 1209, 1212 (1981). In the present case, a prima facie showing of jurisdiction has been met. Plaintiffs have alleged, and Disney has apparently conceded, that Disney has taken a position inconsistent with the use of the *72MGM name for the Las Vegas theme park. Disney’s conduct and actions will substantially interfere with MGM’s proposed park in Nevada.4 See Calder v. Jones, 465 U.S. 783 (1984) (California jurisdiction was available where defendant’s intentional conduct in Florida was calculated to injure a California plaintiff). Under such circumstances, a finding of jurisdiction would comport with the traditional conceptions of “fair play and substantial justice” mandated by International Shoe.

Finally, jurisdiction is present under the test pronounced in Asahi Metal Ind. v. Superior Court of California, 480 U.S. 102 (1987). The Asahi opinion noted that in making a jurisdictional inquiry, a court must consider several factors: (1) the burden on the defendant; (2) the interests of the forum state; (3) the plaintiffs’ interest in obtaining relief; (4) the “interstate judicial system’s interest in obtaining the most efficient resolution of controversies”; and (5) the shared interest in the “several states of furthering fundamental social policies.” Asahi, 480 U.S. at 113.

In the present case, the balance of factors lies in favor of jurisdiction. Disney is a large corporation which can afford to litigate anywhere. Nevada’s interest in a major construction project is strong. Plaintiffs’ interest in a quick adjudication of the issue is also strong. Efficiency concerns support resolving the dispute prior to construction. When considering all these factors, jurisdiction is present under the Asahi test.

Nevada’s long-arm statute does not bar jurisdiction. This court has previously suggested that the intent of the statute is to confer jurisdiction whenever federal due process requirements are met. Davis v. District Court, 97 Nev. 332, 338, 629 P.2d 1209, 1213 (1981).

In Burger King, a Florida corporation obtained jurisdiction in Florida over a Michigan franchisee based upon contract documents, and a relationship with the Miami headquarters. Burger King, 471 U.S. at 487.

In Burger King, the United States Supreme Court stated the following: “So long as a commercial actor’s efforts are ‘purposefully directed’ towards residents of another state, we have consistently rejected the notion that an absence of physical contacts can defeat jurisdiction there.” Burger King, 471 U.S. at 476.

Meanwhile, Disney advertises and promotes its directly competing California and Florida attractions in Nevada on a large scale.