Guam Supreme Court Reverses Superior Court Decision in Larsen v. Hyatt

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Guam – The Supreme Court of Guam today [Thursday] issued an opinion in the case of Larsen v. Hyatt International Corp., 2011 Guam 26, reversing the Superior Court’s decision to dismiss a personal injury case filed against Hyatt International Corporation (“Hyatt International”) and Hyatt Hotels Corporation (“Hyatt Hotels”) by Dennis and Vivian Larsen.

Dennis Larsen, a Guam resident, sprained his ankle while walking off the driveway of the Hyatt Resort and Casino in Manila, Philippines, and he and his wife, Vivian, sued Hyatt International, Hyatt Hotels and John Doe Insurance Companies 1 and 2 in the Superior Court of Guam.

READ the Guam Supreme Court’s Decision in Larsen v. Hyatt

The Larsens served their complaint on Hyatt Regency Guam (“Hyatt Guam”), which was not a defendant in the suit. Although the named defendants Hyatt International and Hyatt Hotels are headquartered outside of Guam, the Larsens asserted that the Superior Court had jurisdiction because Hyatt International and Hyatt Hotels exercised significant control over Hyatt Guam. The Superior Court dismissed the case, holding there was no jurisdiction, and the Larsens appealed.

The Supreme Court reversed, holding that the Superior Court is required to examine the nature of the relationships between Hyatt International, Hyatt Hotel and Hyatt Guam and not rely entirely on the facts provided by Hyatt International and Hyatt Hotels. The case was remanded for limited
jurisdictional discovery on the agency relationship between Hyatt International and Hyatt Hotels and Hyatt Guam.