In addition, plaintiffs cite prior court precedent holding that a corporate defendant that conducts no business within Michigan, but that manages a hotel that is identified with a national hotel chain is subject to limited personal jurisdiction under MCLA § 600.715. Wronikowski v. General Hotels Corporation, 716 F. Supp. 5 (E.D.Mich. 1989). In Wronikowski, a Michigan plaintiff filed suit in the Eastern District of Michigan after he was injured while staying in a Holiday Inn in Indiana.
ECF No. 1 ¶¶ 44-48; ECF No. 30 at 8. Further, the Court notes that affiliation with Marriott provides Juhu with access to a substantial market of American travelers that it might not otherwise reach, Wronikowski v. Gen. Hotels Corp., 716 F.Supp. 5, 6 (E.D. Mich. 1989), “by virtue of the goodwill associated with [the Marriott] brand,” Nandjou v. Marriott Int'l, Inc., 985 F.3d 135 (1st Cir. 2021). All of this is persuasive of purposeful availment.
Rather, there are cases where jurisdiction has been found over out-of-state franchises of a national chain based on the existence of a national presence. See, e.g., Wronikowski v. General Hotels Corp., 716 F. Supp. 5, 6 (E.D. Mich. 1989) (Michigan court had jurisdiction over manager of Indiana Holiday Inn franchise relating to injuries sustained by Michigan resident in Indiana hotel: "Having accepted the benefits of affiliation with a national chain of hotels, defendant must accept the detriments. . . . Having reached out to travelers nationwide, including Michigan travelers, defendant cannot use Holiday Inn as a shield to avoid answering in Michigan's courts."). Accord Kepler v. ITT Sheraton Corp., 860 F. Supp. 393, 397 (E.D. Mich. 1994) (court had long-arm personal jurisdiction over national hotel chain even though defendants did not own any hotels in Michigan).
Rather, there are cases where jurisdiction has been found over out-of-state franchises of a national chain based on the existence of a national presence. See, e.g., Wronikowski v. General Hotels Corp., 716 F. Supp. 5, 6 (E.D. Mich. 1989) (Michigan court had jurisdiction over manager of Indiana Holiday Inn franchise relating to injuries sustained by Michigan resident in Indiana hotel: "Having accepted the benefits of affiliation with a national chain of hotels, defendant must accept the detriments. . . . Having reached out to travelers nationwide, including Michigan travelers, defendant cannot use Holiday Inn as a shield to avoid answering in Michigan's courts."). Accord Kepler v. ITT Sheraton Corp., 860 F. Supp. 393, 397 (E.D. Mich. 1994) (court had long-arm personal jurisdiction over national hotel chain even though defendants did not own any hotels in Michigan).
In this case, Defendant's contacts with Michigan were "twice removed" — it was only by way of having offered rooms for block reservation to Thompson Vacations, an Illinois entity which, in turn, offered package rentals to AAA of Michigan that Defendant had any contact with this state. Wronikowski v. General Hotels Corp., 716 F. Supp. 5 (E.D.Mich. 1989), is likewise distinguishable. In that case, the plaintiff slipped and fell in the bathroom of her Holiday Inn hotel room in Indiana where she was staying during the annual convention of the Midwest Association of Housing Cooperatives (Midwest), which was being held at that Holiday Inn.