Sharon Richards v. Aramark Servs., Inc., F/k/a Ara Servs., Inc., 108 F.3d 925 (8th Cir. 1997). · Go Syfert
Sharon Richards v. Aramark Servs., Inc., F/k/a Ara Servs., Inc., 108 F.3d 925 (8th Cir. 1997). Cases Citing This Book View Copy Cite
51 citation events (46 in the last 25 years) across 11 distinct courts.
Strongest positive: Johnson v. Milstead (sdd, 2025-05-28)
Treatment trajectory · 1998 → 2026 · click a year to view as-of
1998 2012 2026
Top citers, strongest first. 38 distinct citers. How cited ↗
discussed Cited as authority (rule) Johnson v. Milstead
D.S.D. · 2025 · confidence medium
Legal Standard . □ Pursuant to Rule 60(b), a “court may relieve a party .. . from a final judgment” for the following reasons: “(1) mistake, inadvertence, surprise, or excusable neglect . . . or (6) any other reason that justifies relief.” “A district court should grant a Rule 60(b) motion only upon an adequate showing of exceptional circumstances.” Richards v, Aramark Servs., Inc., 108 F.3d 925, 927 (8th Cir. 1997) (cleaned up).
discussed Cited as authority (rule) LeGrand v. Carpenter
D.S.D. · 2025 · confidence medium
“A district court should grant a Rule 60(b) motion only upon an adequate showing of exceptional circumstances.” Richards v. Aramark Servs., Inc., 108 F.3d 925, 927 (8th Cir. 1997) (internal quotation omitted).
discussed Cited as authority (rule) Rindahl v. Reisch
D.S.D. · 2024 · confidence medium
“A district court should grant a Rule 60(b) motion only upon an adequate showing of exceptional circumstances.” Richards v. Aramark Servs., Inc., 108 F.3d 925, 927 (8th Cir. 1997) (internal quotation omitted).
cited Cited as authority (rule) Trammel v. United States
E.D. Mo. · 2024 · confidence medium
Aramark Servs., Inc., 108 F.3d 925, 927 (8th Cir. 1997) (internal quotation omitted).
discussed Cited as authority (rule) Carter v. United States
D.S.D. · 2024 · confidence medium
“A district court should grant a Rule 60(b) motion only upon an adequate showing of exceptional circumstances.” Richards v. Aramark Servs., Inc., 108 F.3d 925, 927 (8th Cir. 1997) (internal quotation omitted).
discussed Cited as authority (rule) E&I Global Energy Services, Inc. v. Liberty Mutual Surety Co.
D.S.D. · 2023 · confidence medium
“A district court should grant a Rule 60(b) motion ‘only upon an adequate showing of exceptional circumstances.’ ” Richards v. Aramark Servs., Inc., 108 F.3d 925, 927 (8th Cir. 1997) (quoting United States v. Tracts 10 & 11 of Lakeview Heights, 51 F.3d 117, 120 (8th Cir. 1995)).
cited Cited as authority (rule) Stompingbear v. Kelley
E.D. Ark. · 2022 · confidence medium
“Relief under Rule 60(b) is limited.” Richards v. Aramark Servs., Inc., 108 F.3d 925, 927 (8th Cir. 1997).
cited Cited as authority (rule) Vient v. Wehco Media Inc
E.D. Ark. · 2022 · confidence medium
“Relief under Rule 60(b) is limited.” Richards v. Aramark Servs., Inc., 108 F.3d 925, 927 (8th Cir. 1997).
discussed Cited as authority (rule) Tieszen v. EBay, Inc.
D.S.D. · 2022 · confidence medium
The court construes the motion under Rule 60(b)(6)’s catch-all provision: “any other reason that justifies relief.” In any event, whether under the catch-all provision or another reason enumerated in the Rule, “[a] district court should grant a Rule 60(b) motion ‘only upon an adequate showing of exceptional circumstances.’ ” Richards v. Aramark Servs., Inc., 108 F.3d 925, 927 (8th Cir. 1997) (quoting United States v. Tracts 10 & 11 of Lakeview Heights, 51 F.3d 117, 120 (8th Cir. 1995)).
discussed Cited as authority (rule) Knode v. Erickson
D.S.D. · 2021 · confidence medium
“A district court should grant a Rule 60(b) motion ‘only upon an adequate showing of exceptional circumstances.’ ” Richards v. Aramark Servs., Inc., 108 F.3d 925, 927 (8th Cir. 1997) (quoting United States v. Tracts 10 & 11 of Lakeview Heights, 51 F.3d 117, 120 (8th Cir. 1995)).
discussed Cited as authority (rule) Connelly v. Dependable Sanitation, Inc.
D.S.D. · 2021 · confidence medium
The court construes the motion under Rule 60(b)(6)’s catch-all provision: “any other reason that justifies relief.” In any event, whether under the catch-all provision or another reason enumerated in the Rule, “[a] district court should grant a Rule 60(b) motion ‘only upon an adequate showing of exceptional circumstances.’ ” Richards v. Aramark Servs., Inc., 108 F.3d 925, 927 (8th Cir. 1997) (quoting United States v. Tracts 10 & 11 of Lakeview Heights, 51 F.3d 117, 120 (8th Cir. 1995)).
discussed Cited as authority (rule) Kreps v. Dependable Sanitation, Inc.
D.S.D. · 2021 · confidence medium
The court construes the motion under Rule 60(b)(6)’s catch-all provision: “any other reason that justifies relief.” In any event, whether under the catch-all provision or another reason enumerated in the Rule, “[a] district court should grant a Rule 60(b) motion ‘only upon an adequate showing of exceptional circumstances.’ ” Richards v. Aramark Servs., Inc., 108 F.3d 925, 927 (8th Cir. 1997) (quoting United States v. Tracts 10 & 11 of Lakeview Heights, 51 F.3d 117, 120 (8th Cir. 1995)).
cited Cited as authority (rule) Hooper v. Esper
E.D. Mo. · 2020 · confidence medium
Co. of Neb., 207 F.3d 480, 487 (8th Cir. 2000); Richards v. Aramark Sesrvs., Inc., 108 F.3d 925, 927 (8th Cir. 1997) (internal quotations and citations omitted).
cited Cited as authority (rule) Biddle v. Bradshaw
W.D. Ark. · 2019 · confidence medium
“Venue requirements exist for the benefit of defendants.” Richards v. Aramark Servs., Inc., 108 F.3d 925, 928 (8th Cir. 1997).
cited Cited as authority (rule) Green Source Holdings, LLC v. Ingevity Corporation
W.D. Ark. · 2019 · confidence medium
“Venue requirements exist for the benefit of defendants.” Richards v. Aramark Servs., Inc., 108 F.3d 925, 928 (8th Cir. 1997).
cited Cited as authority (rule) Thrasher v. Biomet Inc
W.D. Ark. · 2019 · confidence medium
Richards v. Aramark Servs., Inc., 108 F.3d 925, 928 (8th Cir. 1997).
cited Cited as authority (rule) Fox v. DREAM TRUST
D.N.J. · 2010 · confidence medium
Venue requirements “ensure that a defendant is not haled into a remote district, having no real relationship to the dispute.” Richards v. Aramark Services, Inc., 108 F.3d 925, 928 (8th Cir.1997).
discussed Cited as authority (rule) Austin v. Nestle USA, Inc.
D. Minnesota · 2009 · confidence medium
“One of the central purposes of statutory venue is to ensure that a defendant is not ‘haled into a remote district, having no real relationship to the dispute.’ ” Richards v. Aramark Servs., Inc., 108 F.3d 925, 928 (8th Cir.1997) (citation omitted).
discussed Cited as authority (rule) Builders Insurance Group, Inc. v. R.J. Groover Construction, LLC (In Re R.J. Groover Construction, LLC)
Bankr. S.D. Ga. · 2008 · confidence medium
Fed.R.CivJP. 60(b) Relief under Rule 60(b) may be granted “only upon an adequate showing of exceptional circumstances.” In re Michael, 285 B.R. 553, 554 (Bankr.S.D.Ga.2002)(Davis, J.(quoting Richards v. Aramark Servs., Inc., 108 F.3d 925, 927 (8th Cir.1997) (citations omitted)).
discussed Cited as authority (rule) Catholic Order of Foresters v. U.S. Bancorp Piper Jaffray, Inc.
N.D. Iowa · 2004 · confidence medium
Venue statutes “One of the central purposes of statutory venue is to ensure that a defendant is not haled into a remote district, having no real relationship to the dispute.” Richards v. Aramark Servs., Inc., 108 F.3d 925, 928 (8th Cir.1997) (internal quotation marks and citations omitted) (also explaining that “[v]enue requirements exist for the benefit of defendants.”).
cited Cited as authority (rule) Beverly Hogan v. Raytheon Co.
8th Cir. · 2002 · confidence medium
Richards v. Aramark Servs., Inc., 108 F.3d 925, 927 (8th Cir. 1997).
discussed Cited as authority (rule) Beverly Jean Hogan v. Raytheon, Co.
8th Cir. · 2002 · confidence medium
Richards v. Aramark Servs., Inc., 108 F.3d 925, 927 (8th Cir.1997), Subsequent to the district court’s award of attorney fees, this court clarified the applicable law to ERISA’s fee-shifting provision: there is no presumption in favor of a fee award for prevailing ERISA plaintiffs.
discussed Cited as authority (rule) Claude Bennett v. Dr Pepper/seven Up, Inc.
8th Cir. · 2002 · confidence medium
In sum, the District Court’s decision to deny Bennett post-judgment relief was not “based on an erroneous view of the law or a clearly erroneous assessment of the evidence.” Richards v. Aramark Servs., Inc., 108 F.3d 925, 927 (8th Cir.1997).
cited Cited as authority (rule) Martin v. Arkansas Blue Cross And Blue Shield
8th Cir. · 2002 · confidence medium
Richards v. Aramark Servs., Inc., 108 F.3d 925, 927 (8th Cir.1997). 6 This case involves the conundrum of what, exactly, is the applicable law for ERISA attorney fee applications in this circuit.
discussed Cited as authority (rule) Martin v. Arkansas Blue Cross & Blue Shield (2×)
8th Cir. · 2002 · confidence medium
Richards v. Aramark Servs., Inc., 108 F.3d 925, 927 (8th Cir.1997).
discussed Cited as authority (rule) Claude Bennett v. Dr. Pepper/Seven Up
8th Cir. · 2002 · confidence medium
In sum, the District Court's decision to deny Bennett post-judgment relief was not "based on an erroneous view of the law or a clearly erroneous assessment of the evidence." Richards v. Aramark Servs., Inc., 108 F.3d 925, 927 (8th Cir. 1997).
cited Cited as authority (rule) In Re Michael
Bankr. S.D. Ga. · 2002 · confidence medium
Relief under Rule 60(b) may be granted “only upon an adequate showing of exceptional circumstances,” Richards v. Aramark Servs., Inc., 108 F.3d 925, 927 (8th Cir.1997) (citations omitted).
cited Cited as authority (rule) Brian Martin v. AR Blue Cross & Blue
8th Cir. · 2001 · confidence medium
Inc., 108 F.3d 925, 927 (8th Cir. 1997).
discussed Cited as authority (rule) Norma Martin, Brian Martin v. Arkansas Blue Cross and Blue Shield, a Mutual Insurance Company (2×)
8th Cir. · 2001 · confidence medium
Inc., 108 F.3d 925, 927 (8th Cir. 1997).
discussed Cited as authority (rule) Michael D. Trost v. Trek Bicycle Corporation
8th Cir. · 1998 · confidence medium
A. We review the district court’s decision to exclude the opinion of Trost’s expert for abuse of discretion, see Peitzmeier v. Hennessy Indus., Inc., 97 F.3d 293, 296 (8th Cir.1996), cert. denied, — U.S. -, 117 S.Ct. 1552 , 137 L.Ed.2d 701 (1997), and will only reverse if its decision was based on “an erroneous view of the law or a clearly erroneous assessment of the evidence,” Richards v. Aramark Servs., Inc., 108 F.3d 925, 927 (8th Cir.1997).
discussed Cited as authority (rule) Michael D. Trost v. Trek Bicycle Corp.
8th Cir. · 1998 · confidence medium
A. We review the district court’s decision to exclude the opinion of Trost’s expert for abuse of discretion, see Peitzmeier v. Hennessy Indus., Inc., 97 F.3d 293, 296 (8th Cir. 1996), cert. denied, 117 S. Ct. 1552 (1997), and will only reverse if its decision was based on “an erroneous view of the law or a clearly erroneous assessment of the evidence,” Richards v. Aramark Servs., Inc., 108 F.3d 925, 927 (8th Cir. 1997).
discussed Cited as authority (rule) Sanders v. Seal Fleet, Inc.
E.D. Tex. · 1998 · signal: cf. · confidence medium
Time, Inc. v. Manning, 366 F.2d 690, 698 (5th Cir.1966); Myers v. American Dental Ass’n., 695 F.2d 716, 724-25 (3d Cir.), cert. denied, 462 U.S. 1106 , 103 S.Ct. 2453 , 77 L.Ed.2d 1333 (1983); Bounty-Full Entertainment, Inc. v. Forever Blue Entertainment Group, 923 F.Supp. 950, 957-958 (S.D.Tex.1996); cf. Richards v. Aramark Services, Inc., 108 F.3d 925, 928 (8th Cir.1997) (plaintiff has the burden of proving jurisdiction, and dismissal for lack of venue is proper where jurisdiction does not exist); Minnette v. Time Warner, 997 F.2d 1023, 1026 (2d Cir.1993) (plaintiff has to prove that defen…
cited Cited "see" Tb v. Tap
Ala. Civ. App. · 2007 · signal: see · confidence high
See Richards v. Aramark Servs., Inc., 108 F.3d 925, 927 (8th Cir.1997).
cited Cited "see" T.B. v. T.A.P.
Ala. Civ. App. · 2007 · signal: see · confidence high
See Richards v. Aramark Servs., Inc., 108 F.3d 925, 927 (8th Cir.1997).
cited Cited "see" Engineered Products Co. v. Donaldson Co., Inc.
N.D. Iowa · 2004 · signal: see · confidence high
See Richards v. Aramark Services, Inc., 108 F.3d 925, 927 (8th Cir.1997). 3.
cited Cited "see" Hussein Abdi Malin v. Starmark
8th Cir. · 2001 · signal: see · confidence high
See Richards v. Aramark Se rvs., Inc., 108 F.3d 925, 927 (8th Cir.1997) (Fed.R.Civ.P. 60(b) standard of review).
discussed Cited "see" United States v. Balliet
8th Cir. · 2001 · signal: see · confidence high
See Richards v. Aramark Servs., Inc., 108 F.3d 925, 927 (8th Cir.1997) (standard of review); CRI, Inc. v. Watson, 608 F.2d 1137, 1143 (8th Cir.1979) (“[R]elief may be granted under Rule 60(b)(1) for judicial error when inadvertence is shown.”).
cited Cited "see" United States v. James Dale Barnes
8th Cir. · 2000 · signal: see · confidence high
See Richards v. Aramark Services, Inc., 108 F.3d 925, 927 (8th Cir. 1997).
Retrieving the full opinion text from the archive…
Sharon RICHARDS, Plaintiff-Appellant,
v.
ARAMARK SERVICES, INC., F/K/A ARA Services, Inc., Defendant-Appellee
96-2098.
Court of Appeals for the Eighth Circuit.
Mar 17, 1997.
108 F.3d 925
Stephen C. Mackey, argued, Billings, MT (Martha C. McCormack, on the brief), for plaintiff-appellant., Molly A. Horrigan, argued, Chicago IL (James T. Laffey, on the brief), for defendant-appellee.
Magill, McMILLIAN, Webber.
Cited by 40 opinions  |  Published
WEBBER, District Judge.

Sharon Richards appeals from the district court’s [2] orders dismissing her claims for improper venue and denying her motion for relief sought under Rule 60(b) of the Federal Rules of Civil Procedure after the district court granted defendants’ motion to dismiss for improper venue. We affirm.

[*927] I.

Sharon Richards, a Montana resident, was injured at O’Hare International Airport in Chicago, Illinois, on October 3, 1988, while delivering freight as a long-haul truck driver. On September 30, 1994, after the statute of limitations barred her negligence action in Illinois, she filed suit in the District Court of Minnesota where the action was not time-barred. Named as defendants were Ground Services, Inc. (hereinafter referred to as “GSI”), and ARA, later Aramark Services, Inc. (hereinafter referred to as “Aramark”). GSI moved to dismiss the action for lack of personal jurisdiction under Rule 12(b)(2) of the Federal Rules of Civil Procedure and under Minnesota’s long-arm statute. Additionally, both defendants moved to dismiss the action for lack of proper venue pursuant to Fed.R.Civ.P. 12(b)(3) and 28 U.S.C. § 1391(a)(3).

Richards then filed an “alternative motion” to change venue to the District Court for the District of Illinois, under 28 U.S.C. § 1404(a). Richards’ motion requested the eourt to transfer venue to the Northern District of Illinois if the court first determined the eourt lacked personal jurisdiction over GSI or that venue was improper in Minnesota. At the beginning of a hearing on February 2, 1996, Richards’ counsel withdrew the § 1404(a) motion, but did not voluntarily dismiss GSI from the suit. After the hearing, the district court dismissed plaintiffs action for improper venue. Plaintiff filed a motion for post-judgment relief under Rules 59, 60(a), 60(b)(1) and 60(b)(6) of the Federal Rules of Civil Procedure. That motion was denied. On appeal, plaintiff claims the district eourt abused its discretion in denying her motion for post-judgment relief under Fed.R.Civ.P. 60(b)(1).

II.

We review the district eourt order denying relief under Fed.R.Civ.P. 60(b)(1) for abuse of discretion. Abuse of discretion will be found only when the trial court’s decision is based on an erroneous view of the law or a clearly erroneous assessment of the evidence. Waible v. McDonald’s Corp., 935 F.2d 924, 926 (8th Cir.1991). Abuse of discretion can occur in three principal ways:

when a relevant factor that should have been given significant weight is not considered; when an irrelevant or improper factor is considered and given significant weight; and when all proper factors, and no improper ones, are considered, but the court, in weighing those factors, commits’ clear error of judgment.

Williams v. Carter, 10 F.3d 563, 566 (8th Cir.1993) (quoting Kern v. TXO Prod. Corp., 738 F.2d 968, 970 (8th Cir.1984)).

Relief under Rule 60(b) is limited. “A district court should grant a Rule 60(b) motion ‘only upon an adequate showing of exceptional circumstances.’ ” United States v. Tracts 10 & 11 of Lakeview Heights, 51 F.3d 117, 120 (8th Cir.1995) (quoting United States v. Young, 806 F.2d 805, 806 (8th Cir. 1986), cert. denied, 484. U.S. 836, 108 S.Ct. 117, 98 L.Ed.2d 76 (1987)); see also General Elec. Co. v. Lehnen, 974 F.2d 66, 67 (8th Cir.1992) (relief under Rule 60(b) to be granted only in exceptional cases). We find no application of an erroneous view of the law or erroneous assessment of evidence by the district court, nor do exceptional circumstances justify relief under Rule 60(b)(1).

Richards asserts that she was entitled to Rule 60(b) relief because of existence of confusion at the hearing on February 2, 1996, and in the district court’s refusal to grant remedial relief. Her claim is not supported by the record. Plaintiff filed suit in Minnesota to take advantage of its statute of limitations. Once defendants challenged venue and personal jurisdiction, plaintiff sought, through her motion, a transfer to the Northern District of Illinois under 28 U.S.C. § 1404(a). Transfer of venue under this section would have allowed the longer Minnesota statute of limitations to be applied in Illinois. A transfer under 28 U.S.C. § 1404(a) turns on considerations of convenience and the interest of justice and when granted, the transferee forum is required to apply the law of the transferor state. Ferens v. John Deere Co., 494 U.S. 516, 523, 110 S.Ct. 1274, 1279-80, 108 L.Ed.2d 443 (1990). However, Richards wanted to avoid transfer of venue pursuant to 28 U.S.C. § 1406(a).[*928] Under that section, the Illinois statute of limitations would have applied and her action would have clearly been time-barred.

At the hearing, Richards’ counsel argued exhaustively that she had acquired personal jurisdiction over GSI by a reverse-piercing, alter-ego theory, [3] having first acquired confessed in personam jurisdiction over Aramark. However, as the district court properly determined, Richards never acquired personal jurisdiction over GSI or its successor, Ogden Ground Services. [4] At the conclusion of the arguments at the February 2 hearing, the district judge announced an intent to grant the motion for lack of venue filed by defendants. When asked by Richards’ counsel if that applied to GSI, the judge confirmed that it did, then added that “this is not the place this lawsuit ought to go on.” The court then offered Richards’ counsel an opportunity to react and asked, “Do you want to do something now, or are you going to bring a subsequent motion somewhere else?” (emphasis added). Richards’ counsel offered no oral or written motion, but suggested that the court should rule the issue of jurisdiction “before it was appropriate to address the transfer of the remaining case.” However, because the motion to transfer was withdrawn at the beginning of the court’s dismissal hearing, the issue was no longer before the court. On that same day, the district court issued a written order dismissing the action for improper venue.

Richards filed her action in the district court of Minnesota as a harbor with a longer statute of limitations. Once there, when personal jurisdiction was challenged, the burden did not shift to defendants. Gould v. P.T. Krakatau Steel, 957 F.2d 573, 575 (8th Cir.) (burden of proof is on the party seeking to establish the court’s in personam jurisdiction and does not shift to party challenging jurisdiction), cert. denied, 506 U.S. 908, 113 S.Ct. 304, 121 L.Ed.2d 227 (1992). The motion to dismiss for lack of personal jurisdiction filed by defendants was considered and ruled adversely to Richards. Likewise, the district court considered the other pending motions to dismiss for improper venue. “Venue requirements exist for the benefit of defendants.” Hoover Group, Inc. v. Custom Metalcraft, Inc., 84 F.3d 1408, 1410 (Fed.Cir.1996) (citing VE Holding Corp. v. Johnson Gas Appliance Co., 917 F.2d 1574, 1576 (Fed.Cir.1990), cert. denied, 499 U.S. 922, 111 S.Ct. 1315, 113 L.Ed.2d 248 (1991)). “One of the central purposes of statutory venue is to ensure that a defendant is not ‘haled into a remote district, having no real relationship to the dispute.’” Woodke v. Dahm, 70 F.3d 983, 985 (8th Cir.l995)(quoting Cottman Transmission Sys., Inc. v. Martino, 36 F.3d 291, 294 (3d Cir.1994)). In this diversity action, without personal jurisdiction over both defendants in the State of Minnesota, venue was improper. See 28 U.S.C. § 1391(a). The district court, after concluding it had no personal jurisdiction over GSI, properly dismissed the action because venue was improper. All named defendants clearly did not reside in the State of Minnesota.

[*929] Richards controlled the course of the litigation against Aramark in the district court of Minnesota. She could have voluntarily dismissed her claims against GSI and proceeded with her action against Aramark, seeking, if she chose, to attempt to transfer venue to the Northern District of Illinois under 28 U.S.C. § 1404(a), while maintaining the benefit of the Minnesota statute of limitations. She had on file a motion to transfer venue in the event the court found no personal jurisdiction existed as to GSI, but she withdrew that motion at the beginning of the hearing. When the district court later determined at the hearing that it had no personal jurisdiction over GSI, the only two pending motions in the case were defendants’ motion to dismiss for lack of personal jurisdiction over GSI and defendants’ motion to dismiss for improper venue. Without personal jurisdiction over GSI, venue was necessarily improper under 28 U.S.C. 1391(a).

Richards seems to be arguing that the district court should have paused after ruling the personal jurisdiction issue as to GSI to permit her to proffer a motion she had already withdrawn. The court entreated plaintiff to take action after indicating it was going to rule defendants’ motion challenging venue. A district court has no duty to take the action she requests. Woodke, 70 F.3d at 986, (in absence of motion by plaintiff to dismiss certain defendants in order to preserve venue, district court is not required to dismiss such defendants sua sponte).

Review of the transcript and the district court’s order dismissing the action reveals a well-reasoned application of the law by the district judge on the pending motions. We find no abuse of discretion by -the district judge in denying Richards’ motion for reconsideration.

The orders of the district court are affirmed.

2

. The Honorable David S. Doty, United States District Judge for the District of Minnesota.

3

. In a reverse-piercing situation, a corporate entity is set aside so the protections and rights available to non-corporate entities or individuals are made available to the corporation's insiders or shareholders. See In Re Schuster, 132 B.R. 604, 607 (Bankr.D.Minn.1991); Miller & Schroeder, Inc. v. Gearman, 413 N.W.2d 194, 198-201 (Minn.Ct.App.1987). In every case cited by Richards applying reverse piercing under Minnesota law, relief was sought by a shareholder of a corporation. See Cargill, Inc. v. Hedge, 375 N.W.2d 477, 479-80 (Minn.1985); Kuennen v. Citizens Security Mut. Ins. Co., 330 N.W.2d 886, 887 (Minn.1983); Roepke v. Western Nat’l Mut. Ins. Co., 302 N.W.2d 350, 352-53 (Minn. 1981); State Bank v. Euerle Farms, Inc., 441 N.W.2d 121, 124 (Minn.Ct.App. 1989). Richards is admittedly not a shareholder of either Aramark or GSI. Richards cites no authority to support her application of the reverse-piercing theory to gain personal jurisdiction over GSI through Aramark and the Court does not find any reason for applying such a theory under the circumstances of this action.

4

. On October 31, 1988, GSI was a Delaware corporation with principal offices in Miami, Florida. In September, 1990, all GSI stock was sold to Ogden Ground Services, Inc., a company that is unrelated to Aramark. Neither GSI nor Ogden Ground Services, Inc., transacted business in Minnesota nor had any contact with that state. Thus, the district court correctly determined that there is no basis for in personam jurisdiction over either GSI or Ogden Ground Services, Inc. International Shoe Co. v. Washington, 326 U.S. 310, 316, 66 S.Ct. 154, 158, 90 L.Ed. 95 (1945).