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 for lack of 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 based solely on convenience or the fact that litigation could proceed in the forum state. The court applied a strict standard of necessity, interpreting the statutory phrase “ends of justice require” to mean that service on out-of-state defendants is permitted only when it is absolutely necessary to bring all co-conspirators before a single court. Because the nine Florida-based Trivest defendants had zero contacts with Michigan and could be sued in Florida alongside the North Carolina defendant, the court found that convenience factors—such as the case’s duration or the availability of counsel in Michigan—were insufficient to satisfy the necessity requirement. Consequently, the district court lacked the power to adjudicate the claims against these nonresident entities. As a practical consequence, the district court’s September 12, 2023 order denying the defendants’ motion to dismiss is reversed, and the case is remanded with instructions to dismiss the claims against the Florida-based Trivest defendants for lack of personal jurisdiction. Additionally, the Sixth Circuit vacated the district court’s May 23, 2025 order denying motions to compel arbitration regarding those same defendants, as the district court lacked the authority to rule on such motions without personal jurisdiction over the parties involved. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.