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ARA Incorporated v. City of Glendale

2018 WL 1411787 (D. Ariz. 2018)

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ARA Incorporated v. City of Glendale

United States District Court for the District of Arizona
2018 WL 1411787 (D. Ariz. 2018)

SC

Facts

In 2011, ARA Incorporated (ARA) (plaintiff) signed a factoring agreement with JG Staffing under which it purchased JG Staffing’s accounts receivable. The agreement did not contain an after-acquired-property clause. The agreement stated that Minnesota law would apply to any disputes under the agreement. In 2015, ARA sued JG Staffing for breach of the factoring agreement and won a judgment of approximately $700,000. Later in 2015, JG Staffing signed a new staffing contract with the City of Glendale (defendant). ARA contacted Glendale, informing the city of its factoring agreement with JG Staffing. Despite the agreement, Glendale declined to pay ARA directly, and ARA sued Glendale for breach of the Uniform Commercial Code (UCC). Glendale filed a motion to dismiss, asserting that ARA’s factoring agreement with JG Staffing had no relation to or impact on Glendale’s agreement with JG Staffing.

Rule of Law

Issue

Holding and Reasoning (Snow, J.)

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