No personal jurisdiction when . . .

Jones, the heir of a former member of the Dixie Cups, a Louisiana-based musical group, sued the Artist Rights Enforcement Corporation in Louisiana for mishandling royalties. The Fifth Circuit affirmed the dismissal of Jones’s case for lack of personal jurisdiction, observing:

• The contract was not signed in Louisiana;
• “Even if the contract was discussed and drafted in Louisiana, the exchange of communications in carrying out a contract is not enough to establish personal jurisdiction”;
• Jones had nothing to do with any Louisiana-based discussions in any event;
• “When royalties were collected, they were sent to New York and stored in a New York bank”; and
• “Although AREC sent payments to Louisiana, this [was] . . . only because [the former band member] resided there, which fails to establish purposeful minimum contacts.”

Jones v. Artists Rights Enf. Corp., No. 19-30374 (Oct. 22, 2019) (unpublished).