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Tuesday, May 19, 2026

Jurisdiction – Remote employment – Purposeful availment - Massachusetts Lawyers Weekly

Where a Massachusetts plaintiff has alleged nonpayment of wages, the complaint should be dismissed for lack of personal jurisdiction, as the two Florida-based defendants did not purposefully avail themselves of the privilege of conducting activities in the commonwealth.

“Plaintiff Joel Fuller (‘Fuller’) brings this action against his former employers, Carrera & Partners, Inc. (‘Carrera & Partners’) and its president, Nick (Dominic) Carrera (‘Nick Carrera’ or ‘Carrera’) (together, ‘Defendants’), asserting claims related to the termination of his employment. Before the Court is Defendants’ motion to dismiss Fuller’s complaint, … pursuant to Federal Rule of Civil Procedure 12(b)(2) for lack of personal jurisdiction. …

“Plaintiff Joel Fuller resides in Medway, Massachusetts. … Defendant Carrera & Partners, an automobile advertising agency, is a Florida corporation with a principal place of business in Deerfield Beach, Florida. … Defendant Nick Carrera, a Florida resident, was the company’s president at all relevant times. …

“… Here, Fuller’s claims, all of which are related to the alleged nonpayment of wages by Defendants, are sufficiently based on Defendants’ contacts directed to Fuller in Massachusetts, in particular Nick Carrera’s phone call terminating Fuller’s employment. …

“The Court finds that due process nonetheless bars this Court’s exercise of specific jurisdiction over Defendants, because Defendants’ Massachusetts contacts do not ‘represent a purposeful...



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