A California appellate court has upheld a lower court's decision to quash service of a summons and complaint against a New Mexico resident, highlighting the complexities of jurisdiction in multi-state legal disputes. On August 30, 2024, Ernest J. Franceschi, Jr., an attorney representing himself, filed an appeal in the Second Appellate District of California after the Los Angeles County Superior Court ruled it lacked personal jurisdiction over Gloria Baldwin.
The case revolves around allegations made by Franceschi against Christopher Baldwin and his mother, Gloria Baldwin. Franceschi claimed that he had represented Christopher in two lawsuits funded by Christopher's father. According to Franceschi, both Baldwins refused to settle or mediate these lawsuits, prompting him to withdraw as counsel. Subsequently, Christopher allegedly sent an email demanding the return of funds paid to Franceschi under threat of reporting him to the IRS and State Bar. Franceschi accused Gloria Baldwin of conspiring with her son and being a "driving force behind the extortionate email."
Gloria Baldwin responded by filing a motion to quash service on grounds that the California courts lacked jurisdiction over her. In her declaration, she stated that she was a lifelong resident of New Mexico with no ties to California—no property ownership, bank accounts, or business dealings in the state. She also noted that while she had signed as a guarantor for her son's apartment lease in Marina del Rey in 2015, she neither resided there nor paid his rent.
The trial court allowed Franceschi limited discovery to depose Ms. Baldwin on jurisdictional issues but ultimately found his evidence insufficient for establishing either general or specific jurisdiction over her. The court noted that Franceschi's lawsuit did not relate to Ms. Baldwin’s involvement in her son's lease agreements and found no substantial contacts between Ms. Baldwin and California.
Franceschi argued that Ms. Baldwin's repeated guarantees for her son's leases constituted "substantial, continuous, and systematic" contacts with California sufficient for general jurisdiction. However, the court rejected this argument, citing legal precedents that mere guaranty relationships do not establish jurisdiction.
In affirming the lower court's decision, the appellate court highlighted key legal principles governing personal jurisdiction over non-residents: minimum contacts must exist such that asserting jurisdiction does not violate traditional notions of fair play and substantial justice. The court found no evidence suggesting Ms. Baldwin purposefully availed herself of benefits from California or engaged in activities justifying general or specific jurisdiction.
Franceschi also contended that Ms. Baldwin should be subject to California law due to her alleged control over Enterprise Builders—a New Mexico construction company—and its purported employment of Christopher Baldwin in California. However, this argument was dismissed due to lack of supporting evidence and relevance to establishing personal jurisdiction.
Ultimately, the appellate court concluded that Franceschi failed to meet his burden of proof regarding Ms. Baldwin’s significant connections with California necessary for exercising personal jurisdiction.
Representing himself pro se was Ernest J. Franceschi Jr., while Davis Wright Tremaine attorneys Mary H. Haas, Daniel H. Leigh, and Mark C. Burnside represented Gloria Baldwin before Judge Michelle Williams Court at Los Angeles County Superior Court under Case ID B323870.