Alleged Use of Phila.-Based Facebook Group Means Civil Fraud Suit Stays in Pa.
A South Carolina woman accused of selling MetroPCS phones through Facebook should face civil charges in Pennsylvania, a federal court has ruled.
February 22, 2018 at 02:23 PM
3 minute read
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A South Carolina woman accused of selling MetroPCS phones through Facebook should face civil charges in Pennsylvania, a federal court has ruled, finding that her alleged use of Philadelphia-based social media sites meant the Keystone State had jurisdiction over the case.
U.S. District Judge Michael Baylson of the Eastern District of Pennsylvania on Wednesday rejected defendant Nina Stewart's motion to dismiss the case MetroPCS v. Thomas for lack of personal jurisdiction. Although Stewart contended that she has not lived in Pennsylvania for more than 20 years, Baylson said that Pennsylvania had an interest in hearing the civil suit since Stewart allegedly used Philadelphia-specific Facebook groups to sell the phones.
“Plaintiff has shown that Stewart expressly aimed her tortious conduct at Pennsylvania because it alleges that Stewart posted these ads on groups targeting Philadelphia-area buyers and sellers purposely and did so in 57 out of 60 of her advertising posts,” Baylson said. ”Choosing to post 95 percent of the Facebook ads for phones and handsets to Philadelphia-based groups should make Stewart aware that she may be sued in Pennsylvania and makes jurisdiction in Pennsylvania reasonable.”
According to Baylson, MetroPCS alleged that Stewart's son, Isaiah Thomas, had recruited her to take part in an alleged scheme to sell MetroPCS handsets through their personal Facebook accounts.
Thomas, Baylson said, had previously worked at the electronics retailer, but had been fired after it was discovered he had been teaching customers how to exploit a promotion from another carrier and obtain a much higher-priced smartphone from MetroPCS. After he was fired, Baylson said, he used that method to obtain MetroPCS handsets that he would then sell on Philadelphia-based Facebook groups. MetroPCS sent Thomas a cease-and-desist letter in late 2016, and he subsequently recruited friends and family to help him sell the phones, Baylson said.
Baylson said in the opinion that Stewart's personal Facebook account posted advertisements for the fraudulently obtained phones on the same Philadelphia-based groups' pages Thomas had posted to. Although the electronics retailer also sent Stewart a cease-and-desist letter, the ads continued to appear from her page.
MetroPCS sued for unfair competition, tortious interference, conspiracy, fraud, unjust enrichment, trafficking in computer passwords, trademark infringement and other claims.
Stewart filed a motion to dismiss and a motion for lack of personal jurisdiction, claiming she did not post the ads to her Facebook page and she had not lived in Pennsylvania since 1999.
Baylson noted Metro PCS's allegations that Stewart intentionally posted the ads on Philadelphia-based Facebook pages, and that in one message posted on Stewart's Facebook page said the poster would be back in Philadelphia soon.
Regarding her motion to dismiss, Baylson also noted that at least one ad appeared to be posted from South Carolina.
“This geo-tagged location on the relevant post would seem to contradict Stewart's claim,” Baylson said.
Adam Schwartz of Carlton Fields, who is representing MetroPCS, did not return a call for comment. Stewart, who is representing herself pro se, also did not return a call for comment.
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