Ciolino v. Keystone Shipping Co.

Riccardo Ciolino (plaintiff), a resident of Massachusetts, was employed by Keystone Shipping Co. or its subsidiary, Keystone Management Services, Inc. (collectively, Keystone) (defendants), as a crew member on various ships chartered by Keystone. Keystone was incorporated in Delaware, and its principal place of business was in Pennsylvania. Ciolino initially obtained a job with Keystone by responding to a job posting at the National Maritime Union Boston Local. For later jobs on Keystone ships, Keystone reached out to Ciolino at his home. Ciolino worked on various ships for Keystone for more than a decade. In 2019 Ciolino’s health declined, and he was diagnosed with benign asbestos pleural effusion. Ciolino sued Keystone, Chesapeake Shipping, Inc., Chilbar Shipping Company (Chilbar), Margate Shipping Company (Margate), and Keystates Inc. (defendants) in the United States District Court for the District of Massachusetts, alleging that his illness was caused by exposure to asbestos on several of Keystone’s ships. Keystone, Chilbar, Margate, and Keystates moved to dismiss Ciolino’s complaint for lack of personal jurisdiction. Ciolino opposed the motion and alternatively sought to conduct jurisdictional discovery. The court limited its analysis of personal jurisdiction to Keystone because Ciolino alleged that Keystone owned or controlled the other defendants.