In Bristol-Myers Squibb Co. v. Superior Court of California, San Francisco Cty., the U.S. Supreme Court established limitations on personal jurisdiction over non-resident defendants in “mass actions,” effectively supporting the view that plaintiffs cannot simply “forum shop” in large class and collective actions and instead must sue where the corporate defendant has significant contacts for purposes of general jurisdiction or limit the class definition to residents of the state where the lawsuit is filed.  Notably, the Supreme Court’s decision was limited to personal jurisdiction issues in state courts, which has led to a split on the question of whether, and to what extent, the Supreme Court’s analysis applies to class and collective actions pending in federal court. 
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According to the National Human Trafficking Hotline, California has had the highest number of reported cases of human trafficking in the country over the last six years, followed by Texas and Florida.  Recent studies indicate that hotels and motels are common locations for sex trafficking. In light of these startling statistics, now is a good time for employers to become informed about new legislation associated with human trafficking crimes and to implement or update their anti-human trafficking policies and practices.
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