Rhode Island Court Dismisses Boat Sale Dispute for Lack of Jurisdiction

Judge rules defendant did not purposefully conduct activities in Rhode Island

Mar. 18, 2026 at 10:30pm

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A Rhode Island federal judge dismissed a case for lack of jurisdiction in a boat sale broker dispute, ruling the court lacked jurisdiction since the defendant, who was located in New Jersey, did not engage in activities in Rhode Island.

Why it matters

This case highlights the importance of establishing personal jurisdiction in civil lawsuits, especially when the parties and transactions are located out-of-state. The judge's ruling emphasizes that merely knowing the plaintiff is located in a particular state is insufficient to establish jurisdiction over the defendant.

The details

The plaintiff, a Rhode Island-based boat broker, filed a complaint against a New Jersey defendant over the sale of a boat from a New York seller to the New Jersey buyer. However, the judge ruled that the plaintiff failed to show the defendant purposefully availed himself of the privilege of conducting activities in Rhode Island, as required to establish specific personal jurisdiction. The judge noted that none of the defendant's conduct occurred in or was directed at Rhode Island, and the entire transaction took place out of state.

  • The complaint was filed in 2026.

The players

Judge Mary S. McElroy

A U.S. District Court judge who presided over the case and issued the dismissal ruling.

Plaintiff

A Rhode Island-based boat broker who filed the complaint against the defendant.

Defendant

A New Jersey resident who was the buyer in the boat sale transaction.

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What they’re saying

“Asserting that a defendant's actions in different states and online had trickle-down effects on a plaintiff doing business in Rhode Island is insufficient to satisfy specific personal jurisdiction.”

— Judge Mary S. McElroy

“Mere knowledge that the plaintiff is living or operating in a particular state is insufficient.”

— Judge Mary S. McElroy

What’s next

The plaintiff may choose to refile the case in a jurisdiction where the court has proper personal jurisdiction over the defendant.

The takeaway

This case underscores the complexities of establishing personal jurisdiction, especially in disputes involving parties and transactions located in different states. It serves as a reminder for businesses and individuals to carefully consider jurisdictional requirements when pursuing legal action against out-of-state parties.