Billion Law, representing Alliance Global Solutions, LLC, secured a favorable ruling in Dozier v. Alliance Global Solutions, LLC, 24-cv-348 (M.D. Tenn.), before the Middle District of Tennessee. The case involved the application of Mallory v. Norfolk Southern Railway Co. to Tennessee’s statute requiring out-of-state corporations to register with the Secretary of State.

The plaintiff argued that the Tennessee corporate registration statute conferred personal jurisdiction over the defendant under the Mallory decision. However, the Court declined to make an Erie guess regarding whether the Tennessee statute provided such jurisdiction. Instead, the Court ruled that personal jurisdiction could only be established if (i) the statute explicitly conferred jurisdiction or (ii) state courts had previously determined that the registration regime conferred Mallory jurisdiction. In its decision, the Court noted, "The absence of such decision is dispositive in and of itself."

Billion Law was assisted by Tennessee counsel from Riley & Jacobson, including Katharine Klein and James Bowen. This ruling provides clarity on the limitations of corporate registration statutes in Tennessee, particularly in the context of personal jurisdiction claims under Mallory. The decision marks an important interpretation of the jurisdictional reach of Tennessee's statutory framework for out-of-state corporations.

‍

‍