Domicile Confers General Jurisdiction Over Individuals, While Undeveloped Personal-Jurisdiction Theories Are Waived on Appeal

I. Introduction

In T. H. Glennon Co., Inc. v. Monday (1st Cir. Apr. 17, 2026) (unpublished), the First Circuit reviewed a Massachusetts federal district court’s post-trial dismissal—without prejudice—of remaining claims against several defendants for lack of personal jurisdiction.

The plaintiff, T.H. Glennon Co., Inc. (“Glennon”), alleged that its former salesman, Shonn Monday, breached a non-disclosure agreement by misappropriating confidential information and helping launch a competing business in the mulch coloring/landscaping equipment market. Glennon sued Shonn and additional defendants it believed were involved: Shonn’s wife Debra Monday (a Massachusetts resident), their company TMG Green, LLC, and New York-based H.U.R.B. Landscaping, Inc. and its officer Ulderic Boisvert.

After a bench trial against Shonn alone (resulting in liability findings against him), the district court dismissed the stayed claims against the remaining defendants for lack of personal jurisdiction. On appeal, Glennon achieved a narrow but important correction: the First Circuit held that dismissing Debra Monday for lack of personal jurisdiction was erroneous, but it affirmed the dismissals of the out-of-state defendants because Glennon’s appellate presentation of jurisdictional theories was largely waived or inadequately developed.

II. Summary of the Opinion

Reversed as to Debra Monday: the district court had general personal jurisdiction over her as a Massachusetts domiciliary served in Massachusetts.
Affirmed as to H.U.R.B. Landscaping, Inc. and Ulderic Boisvert: Glennon’s theories for personal jurisdiction failed due to waiver and insufficient briefing.
No revival of claims against TMG Green, LLC: Glennon did not brief any argument regarding that entity.
Jurisdictional discovery denial upheld: without a colorable, preserved jurisdictional theory, Glennon could not show “manifest injustice.”

III. Analysis

A. Precedents Cited (and How They Shaped the Outcome)

1. General jurisdiction over individuals: domicile as the “paradigm forum”

The reversal as to Debra Monday turned on a straightforward application of Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915, 924 (2011), quoted by the panel for the proposition that “[f]or an individual, the paradigm forum for the exercise of general jurisdiction is the individual’s domicile.” Debra was a Massachusetts resident served at her Massachusetts home; the district court therefore had general jurisdiction over her, making the prior dismissal legally untenable.

2. Appellate waiver for undeveloped arguments

The bulk of the opinion is a cautionary roadmap of waiver doctrine in the First Circuit:

Rodríguez-Machado v. Shinseki, 700 F.3d 48, 49 (1st Cir. 2012): cited to underscore that arguments may be waived where a party cites “no caselaw at all” and fails to develop the issue.
Doherty v. Merck & Co., 892 F.3d 493, 501 (1st Cir. 2018): used repeatedly for the proposition that a “skimpy effort” and failure to respond meaningfully (including in a reply brief) can waive issues.
Hannon v. Beard, 524 F.3d 275, 279 (1st Cir. 2008): invoked to emphasize that the appellant must provide the “necessary caselaw” and “reasoned analysis,” not conclusory assertions.
Rodríguez v. Mun. of San Juan, 659 F.3d 168, 175-76 (1st Cir. 2011): relied on to reject “buzzwords” and to hold that raising meaningful legal analysis only in a reply brief is “too little.”
United States v. Mojica-Ramos, 103 F.4th 844, 849 n.3 (1st Cir. 2024): cited for the “too late” principle—arguments meaningfully developed only on reply are typically forfeited.
United States v. Zannino, 895 F.2d 1, 17 (1st Cir. 1990): the court refuses to “do counsel’s work” by constructing the legal framework the party failed to provide.
Ward v. AlphaCore Pharma, LLC, 89 F.4th 203, 211 (1st Cir. 2023): quoted (“thinnest of gruel”) to emphasize that complex issues require substantive support.

3. Civil RICO pleading, predicate acts, and particularity

Glennon attempted to use civil RICO as a jurisdictional hook (via nationwide service/personal jurisdiction), but the panel treated the point as waived because Glennon did not adequately explain why the district court erred in dismissing the RICO claim in the first place:

Lerner v. Colman, 26 F.4th 71, 76-77 (1st Cir. 2022): cited for de novo review of the RICO dismissal and for the requirement that a plaintiff allege at least two RICO predicate acts.
Douglas v. Hirshon, 63 F.4th 49, 55 n.7 (1st Cir. 2023): cited for “heightened particularity requirements” for predicate acts of mail and wire fraud (time, place, and content of communications).

The panel also noted Glennon’s failure to identify which subsection of the RICO jurisdiction statute it relied on, pointing to 18 U.S.C. § 1965 and acknowledging unsettled intra- and inter-circuit disagreement as illustrated by district court decisions such as Naicom Corp. v. DISH Network Corp., Dispensa v. Nat'l Conf. of Cath. Bishops, Licht v. Binance Holdings Ltd., and Mun. of Bayamón v. Exxon Mobil Corp.. The court treated this as precisely the sort of unresolved doctrinal thicket that requires careful briefing—briefing Glennon did not provide.

4. The First Circuit’s specific personal jurisdiction framework

In rejecting Glennon’s “prima facie” specific-jurisdiction argument as waived, the court anchored itself in the First Circuit’s standard test:

Motus, LLC v. CarData Consultants, Inc., 23 F.4th 115, 122-24 (1st Cir. 2022): cited for the three-part specific jurisdiction inquiry—relatedness, purposeful availment, and reasonableness—and for the distinction between purposeful-availment foreseeability and the separate reasonableness prong.
Scottsdale Cap. Advisors Corp. v. The Deal, LLC, 887 F.3d 17, 20 (1st Cir. 2018): cited for the rule that failure on any one prong defeats specific jurisdiction.
Chen v. U.S. Sports Acad., Inc., 956 F.3d 45, 54 (1st Cir. 2020): cited regarding the prima facie standard and the need for “properly documented” evidentiary proffers, as well as complications when a record has developed (here, a trial occurred as to a different defendant).

The opinion also contextualized these requirements with the First Circuit’s repeated observation that personal jurisdiction is doctrinally difficult: Rosenthal v. Bloomingdales.com, LLC, 101 F.4th 90, 98 (1st Cir. 2024) (Thompson, J., concurring dubitante) (cleaned up), and Donatelli v. Nat'l Hockey League, 893 F.2d 459, 462 (1st Cir. 1990).

5. Conspiracy theory of personal jurisdiction: not adopted (and not briefed)

Glennon urged adoption of the “conspiracy theory of personal jurisdiction,” but the panel declined, emphasizing both the unsettled status and Glennon’s failure to address threshold statutory and due process questions:

Glaros v. Perse, 628 F.2d 679, 682 & n.4 (1st Cir. 1980): described the theory and its “something more” requirement; also cited to show the First Circuit had previously passed on adopting it.
Van Schaick v. Church of Scientology of Cal., Inc., 535 F. Supp. 1125, 1132 (D. Mass 1982): cited for the proposition that Massachusetts had not adopted the theory and that courts applying it generally tie it to a forum long-arm statute.
In re Lupron Mktg. & Sales Pracs. Litig., 245 F. Supp. 2d 280, 294 (D. Mass. 2003): cited as suggesting the theory may not comport with federal due process.
In re TelexFree Sec. Litig., 626 F. Supp. 3d 253, 285 (D. Mass. 2022), and Ward v. Auerbach, No. CV 16-12543-FDS, 2017 WL 2724938, at *12-13 & n.8 (D. Mass. June 23, 2017), aff'd sub nom., Ward v. AlphaCore Pharma, LLC, 89 F.4th 203 (1st Cir. 2023): cited to show continuing uncertainty and a tendency to assume arguendo rather than adopt the theory.

6. Jurisdictional discovery: “colorable” jurisdiction claim required; reversal standard is high

The panel rejected Glennon’s complaint that it was entitled to jurisdictional discovery:

Sunview Condo. Ass'n v. Flexel Int'l, Ltd., 116 F.3d 962, 964 (1st Cir. 1997): acknowledged that a diligent plaintiff with a “colorable case” for jurisdiction may be entitled to a “modicum” of jurisdictional discovery.
United States v. Swiss Am. Bank, Ltd., 274 F.3d 610, 626 (1st Cir. 2001): supplied the controlling, demanding standard for reversal— only upon “manifest injustice,” where the denial was “plainly wrong” and caused “substantial prejudice.”

Because Glennon waived its substantive jurisdiction theories on appeal, it necessarily failed to show a preserved, “colorable” basis for personal jurisdiction, making the discovery denial particularly difficult to disturb under Swiss Am. Bank.

B. Legal Reasoning

1. Clean correction: Debra Monday and general jurisdiction

The court treated the dismissal of Debra Monday as an uncomplicated legal error: a Massachusetts domiciliary served in Massachusetts is subject to the forum’s general jurisdiction. The panel reversed and remanded, expressly leaving room for the district court to consider any non-jurisdictional defenses Debra had raised.

2. The out-of-state defendants: the court enforced briefing discipline

For H.U.R.B. and Boisvert, the opinion is less about choosing among competing jurisdiction doctrines and more about enforcing appellate requirements. The panel repeatedly emphasized that personal jurisdiction analysis is structured and prong-specific; to obtain reversal, an appellant must (a) identify a viable legal theory and (b) walk through the governing test with supporting authority and reasoned application to record facts.

Glennon failed that task in several ways the court deemed independently dispositive:

RICO jurisdiction theory: Glennon did not adequately contest the RICO dismissal (predicate acts and Rule 9(b)-style particularity issues), did not cite RICO precedent, did not identify the relevant subsection of 18 U.S.C. § 1965, and did not meaningfully engage with appellees’ counterarguments.
Specific jurisdiction theory: Glennon largely ignored the three-part Motus, LLC v. CarData Consultants, Inc. framework in its opening brief, failed to address reasonableness at all, and attempted to patch deficiencies in reply (too late).
Conspiracy jurisdiction theory: Glennon raised it for the first time on appeal and did not analyze its compatibility with the Massachusetts long-arm statute or federal due process, despite its own authorities flagging those concerns.
Jurisdictional discovery: Glennon did not grapple with the abuse-of-discretion/manifest-injustice standard and, having waived its jurisdiction theories, could not show a colorable claim warranting discovery.

C. Impact

Reinforces a bright-line personal jurisdiction point for individuals: domiciliaries served in-forum are not plausibly dismissed on personal-jurisdiction grounds. The Debra Monday reversal is a reminder that general jurisdiction over individuals remains comparatively straightforward after Goodyear Dunlop Tires Operations, S.A. v. Brown.
Signals rigorous enforcement of issue preservation in jurisdiction appeals: the decision underscores that personal jurisdiction challenges are framework-driven and authority-dependent. Parties who rely on generalized “contacts” rhetoric, omit prongs (especially reasonableness), or delay analysis until reply risk affirmance without reaching the merits.
Limits strategic reliance on RICO as a jurisdictional shortcut: the opinion highlights two hurdles—(1) pleading a viable RICO claim (including properly pleaded predicate acts), and (2) clearly identifying and supporting the statutory basis for nationwide service/jurisdiction under 18 U.S.C. § 1965, an area the panel recognized as contested.
Preserves flexibility for future litigation through “without prejudice” affirmance: the court noted that Glennon may be able to refile with clearer pleadings or in a forum where jurisdiction is “clear,” limiting claim-preclusion consequences but increasing the premium on careful jurisdictional pleading.

IV. Complex Concepts Simplified

Personal jurisdiction: a court’s power to bind a defendant. If absent, the case (or claims) must be dismissed or moved.
General jurisdiction: “all-purpose” jurisdiction. For individuals, it ordinarily exists where the person is domiciled (their true, fixed home). That is why Massachusetts courts can generally hear claims against Massachusetts residents served in Massachusetts.
Specific jurisdiction: “case-linked” jurisdiction. In the First Circuit, the plaintiff must show (1) the claim is related to the defendant’s forum contacts, (2) the defendant purposefully availed itself of the forum, and (3) exercising jurisdiction is reasonable.
Prima facie standard: an early-stage method for deciding jurisdiction based on properly supported filings (affidavits/documents), with inferences drawn for the plaintiff. But the plaintiff still must connect facts to the legal test’s prongs.
Civil RICO “predicate acts”: a RICO claim typically requires at least two qualifying criminal acts (like certain frauds) forming a pattern. If the alleged predicate acts include mail or wire fraud, the complaint must plead details (time/place/content) with heightened specificity.
Appellate waiver/forfeiture: an appellate court may refuse to consider an argument that is inadequately developed (e.g., no supporting law, no structured analysis, or raised too late).
Jurisdictional discovery: limited discovery to uncover facts relevant to jurisdiction. It is not automatic; it generally requires a “colorable” showing that jurisdiction may exist, and denials are hard to reverse.
Conspiracy theory of personal jurisdiction: a proposed doctrine attributing in-forum acts of one conspirator to out-of-forum conspirators for jurisdictional purposes. The opinion treats it as unsettled in Massachusetts and raises due process concerns.

V. Conclusion

The core doctrinal takeaway is twofold: (1) a federal court sitting in Massachusetts plainly has general personal jurisdiction over a Massachusetts domiciliary served in Massachusetts, making Debra Monday’s dismissal reversible under Goodyear Dunlop Tires Operations, S.A. v. Brown; and (2) as to out-of-state defendants, personal jurisdiction appeals live or die on disciplined application of the governing framework, supported by relevant authority—failures in briefing, prong-by-prong analysis, and issue preservation can lead to affirmance without the court ever reaching the underlying merits.

Note: Although unpublished and expressly described as not breaking new ground, the decision is a practical blueprint for how the First Circuit evaluates (and declines to evaluate) personal jurisdiction arguments when appellate presentation is deficient.