Case Explained: 26a0172p.06

Court: United States Court of Appeals for the Sixth Circuit Filed: 2026-06-16 The Sixth Circuit reversed the district court’s denial of a motion to dismiss based on personal jurisdiction, holding that 18 U.S.C. § 1965(b) does not authorize federal courts to exercise personal jurisdiction over nonresident defendants in civil RICO actions solely for reasons of convenience or when litigation could be conducted in another district where all defendants are subject to suit. The court applied a strict necessity standard, interpreting the statutory phrase “the ends of justice require” to demand that bringing a defendant into a forum lacking minimum contacts be necessary, not merely convenient. While acknowledging that § 1965(b) allows for nationwide service of process to consolidate RICO conspiracies, the court reasoned that convenience factors—such as the case’s duration in the forum, the presence of local counsel, or a balance of hardships—cannot satisfy the “requirement” of necessity when defendants have no contacts with the forum state and could be sued elsewhere. Consequently, the district court lacked the power to adjudicate the Trivest defendants’ motions to compel arbitration; therefore, the court vacated the May 23, 2025 order denying those motions and remanded the case for proceedings consistent with the finding that personal jurisdiction over the Florida-based defendants was improper. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.