Federal Court Has No Jurisdiction Over Title VII/ADEA Claims For Conduct That Occurred In The Netherlands

Ranza v. Nike, Inc., 2015 WL 4282986 (9th Cir. 2015)

Loredana Ranza sued her former employer, Nike European Operations Netherlands, B.V. ("NEON"), and NEON's parent company, Nike, Inc., which is headquartered in Oregon, in federal court in Oregon. All of the alleged discriminatory conduct (involving sex and age discrimination) occurred in the Netherlands. The district court dismissed Ranza's lawsuit for lack of personal jurisdiction over NEON and a failure to state a claim against Nike. The United States Court of Appeals for the Ninth Circuit affirmed, holding that it had no personal jurisdiction over NEON and that the Netherlands provided an adequate and more convenient forum in which to litigate Ranza's claims against Nike under theforum non conveniensdoctrine. The Court rejected Nike's argument that Ranza had failed to exhaust her administrative remedies because of her initial failure to name Nike as a respondent in her EEOC charge.