We are writing about a case that does not involve drugs or
devices because it runs through some of the very same personal
jurisdiction issues we have warned about post-Bauman.
Adams v. NHL, MDL No, 14-2551, Case No. 15-cv-00472
(SRN/JSM), 2019 WL 5079980 (D. Minn. Oct. 10, 2019), is a case from
the NHL concussion MDL. We make a hokey hockey joke in the title
not to minimize the alleged injuries in the cases in this MDL, but
to harken back to the hokey titles in The Rocky and Bullwinkle
Show, the titular characters of which were from Frostbite Falls,
Minnesota. Frostbite Falls was fictional, as were the alleged
general and specific jurisdictional ties of the Adams case
to Minnesota. "Why is personal jurisdiction over a defendant
being litigated in an MDL case?" you ask. Well, the
plaintiff—a Canadian citizen proceeding pro se—filed
directly in the MDL and the defendant reserved its right to contest
jurisdiction when it accepted service for direct filed cases. That
is a
