Aghabekyan et al v. Knight et al

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
GOR AGHABEKYAN, et al.,
Plaintiffs,
v.
CHRISTOPHER KNIGHT, et al.,
Defendants.
___________________________________/
Case No. 1:25-cv-497
Hon. Hala Y. Jarbou
ORDER REGARDING REPORT AND RECOMMENDATION
Plaintiffs Gor Aghabekyan and Armtruck Transport, LLC, bring this lawsuit against
Defendants Christopher Knight and US Motors Corp (USMC). Plaintiffs allege that Defendants
committed conversion and breach of contract by retaining possession of a 2021 Kenworth T880
semi-truck after the expiration of their lease. Defendant USMC did not respond to the complaint
and the Clerk of Court entered default against it on June 18, 2025 (ECF No. 15). Plaintiffs moved
for default judgment against USMC on July 15, 2025 (ECF No. 18). Before the Court is the
magistrate judge’s report and recommendation (R&R) that the Court deny the motion for default
judgment (ECF No. 29). Plaintiffs have filed objections (ECF Nos. 34, 35). For the reasons
explained below, the Court will overrule the objections and deny Plaintiffs’ motion.
The magistrate judge recommended denying the motion for several reasons that Plaintiffs
address in their objections. But it is unnecessary to consider the objections because the Court will
deny the motion on a different basis: it is not clear that the Court has personal jurisdiction over
USMC. A judgment entered without personal jurisdiction over a defendant is void, so the Court
should determine whether it has personal jurisdiction before entering a default judgment. Williams
v. Life Sav. & Loan, 802 F.2d 1200, 1203 (10th Cir. 1986) (“[W]hen entry of a default judgment
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is sought against a party who has failed to plead or otherwise defend, the district court has an
affirmative duty to look into its jurisdiction both over the subject matter and the parties.”); Sinoying
Logistics Pte Ltd. v. Yi Da Xin Trading Corp., 619 F.3d 207, 213 (2d Cir. 2010) (“[W]e agree with
our sister circuits that before a court grants a motion for default judgment, it may first assure itself
that it has personal jurisdiction over the defendant.”); In re Tuli, 172 F.3d 707, 712 (9th Cir. 1999)
(same).
Personal jurisdiction may be general or specific. General personal jurisdiction over a
corporation exists in its state of incorporation and its principal place of business. See Daimler AG
v. Bauman, 571 U.S. 117, 137 (2014). Michigan courts do not have general personal jurisdiction
over USMC because the company is incorporated in and has its principal place of business in
Wyoming. (Am. Compl. ¶ 4, ECF No. 5.) Specific personal jurisdiction exists if a corporation
has “minimum contacts” with a state that are related to the cause of action. Daimler, 571 U.S. at
126–27. Plaintiffs cannot establish specific personal jurisdiction because they do not allege any
connection between USMC and Michigan. For example, they do not allege that the contracts at
issue in the case were executed or performed in Michigan or that the allegedly converted truck is
in, or has ever been in, Michigan. They do allege that “a substantial part of the events or omissions
giving rise to the claims occurred in this District” (Am. Compl. ¶ 7), but this statement is far too
vague to establish personal jurisdiction over USMC in Michigan.
Accordingly,
IT IS ORDERED that Plaintiff’s objections to the R&R (ECF Nos. 34, 35) are
OVERRULED.
IT IS FURTHER ORDERED that the disposition proposed by the R&R (ECF No. 29) is
APPROVED for the reasons set out above. The Court does not adopt the reasoning of the R&R.
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IT IS FURTHER ORDERED that Plaintiffs’ motion for default judgment (ECF No. 18)
is DENIED.
Dated: February 27, 2026 /s/ Hala Y. Jarbou
HALA Y. JARBOU
CHIEF UNITED STATES DISTRICT JUDGE
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