Massachusetts Injury Lawyers Blog
Employees working remotely for out-of-state companies often face complex jurisdictional hurdles when bringing employment-related claims. An opinion recently issued by a Massachusetts court demonstrates how Massachusetts courts evaluate whether they can exercise personal jurisdiction over a foreign or out-of-state employer accused of violating employment rights. If you work remotely from Massachusetts for an out-of-state company and believe your legal rights have been violated, consult a Massachusetts employment attorney to understand where and how your claims can be brought.
Background of the Dispute
It is reported that the plaintiff, a software engineer residing in Massachusetts, filed suit against the defendant, a Delaware company with principal operations outside Massachusetts. The plaintiff alleged breach of contract and violations of Massachusetts wage and employment laws after the termination of his remote employment. The Defendant moved to dismiss the case, asserting a lack of personal jurisdiction under both the Massachusetts long-arm statute and the Due Process Clause of the Fourteenth Amendment.
The plaintiff claimed that although the defendant had no physical offices in Massachusetts, he performed his job entirely from his home in the Commonwealth, attended virtual meetings, and received compensation in Massachusetts. He argued these contacts constituted sufficient business activity to bring the defendant within Massachusetts jurisdiction.
Determining Whether a Court Has Jurisdiction over an Employment Dispute
It is reported that the District Court conducted a two-part analysis: (1) whether the Massachusetts long-arm statute provided a statutory basis for jurisdiction, and (2) whether exercising jurisdiction would comport with constitutional due process.
Under the long-arm statute, jurisdiction may exist where a defendant “transacts any business” in Massachusetts or “contracts to supply services or things” in the Commonwealth. The court examined whether the defendant’s relationship with the plaintiff constituted transacting business in Massachusetts. While the plaintiff’s remote work physically occurred within the state, the company’s operations, management decisions, and clients were all located elsewhere. The court determined that the mere fact of an employee working remotely from Massachusetts did not, without more, establish that the employer transacted business there.
Turning to the due process inquiry, the court considered whether the defendant had “minimum contacts” with Massachusetts such that maintaining the suit would not offend traditional notions of fair play and substantial justice. It analyzed purposeful availment, foreseeability, and relatedness. The court found that the defendant had not purposefully directed activities toward Massachusetts, it did not recruit employees specifically in the Commonwealth, own property there, or otherwise target Massachusetts markets. The decision to allow the plaintiff to work remotely from Massachusetts was for his convenience, not because the defendant sought to conduct business there.
Based on these findings, the court granted Proxet’s motion to dismiss for lack of personal jurisdiction. The court reasoned that although the plaintiff’s presence and performance of work in Massachusetts were undisputed, those unilateral actions did not create jurisdiction over the employer. The company’s limited interactions, electronic communications, and salary payments were insufficient to constitute purposeful availment or to establish that the claims arose from business transacted within the Commonwealth.
Consult a Massachusetts Employment Attorney
Jurisdictional issues can determine whether an employee can even have their case heard. If you work remotely in Massachusetts for a company based elsewhere and believe your employer violated your rights, consulting a knowledgeable employment attorney is essential. James K. Meehan of the Law Office of James K. Meehan is an experienced Massachusetts employment lawyer who can assess your case, determine the proper venue, and advocate for your rights. You can contact Mr. Meehan by calling 508-822-6600 or by filling out the firm’s online form to arrange a consultation.