Henderson v. Woods et al

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
NATALIE HENDERSON CIVIL ACTION
VERSUS No. 25-1254
GLORIA WOODS, ET AL. SECTION I
ORDER & REASONS
Before the Court is plaintiff Natalie Henderson’s (“plaintiff”) motion1 for
reconsideration of this Court’s November 21, 2025 order and reasons (“November
2025 order”).2 Defendants Gloria Woods (“Woods”), UMG Recordings, Inc. (“UMG”),
BMG Rights Management US LLC (“BMG”), W Chappell Music Corp. (“WC Music”),
and CMG Enterprises II, Inc. (“CMG”) (collectively “defendants”) oppose3 the motion.
For the reasons that follow, the Court will deny plaintiff’s motion for reconsideration.
I. BACKGROUND
This case involves a copyright infringement dispute in which plaintiff alleges
damages arising from the defendants’ unauthorized exploitation of plaintiff’s
copyrighted musical work, “Natalie AKA Slimdabodylast NO BBL All Naturalle” (“All
Natural”), through the “[distribution,] creation, release, reproduction, exploitation,
licensing, and public performance” of the musical composition and recording, “Never
Find (Feat. K Carbon)” (“Never Find”).4 Because the Court previously set forth at
1 R. Doc. No. 29.
2 R. Doc. No. 27.
3 R. Doc. No. 30.
4 R. Doc. No. 1, ¶ 12.
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length the factual background of this case,5 the Court assumes the parties’ familiarity
with that background.
On November 21, 2025, this Court issued an order and reasons addressing four
motions.6 Specifically, the Court granted defendants’ motion to dismiss for a lack of
personal jurisdiction pursuant to Federal Rule of Civil Procedure 12(b)(2), dismissed
as moot defendants’ motions to dismiss pursuant to Rules 12(b)(3) and 12(b)(6), and
denied plaintiff’s motion for jurisdictional discovery.7 The Court found that the
plaintiff failed to allege specific facts supporting a prima facie case for either general
or specific personal jurisdiction over the defendants.8
On December 19, 2025, plaintiff filed the instant motion for reconsideration,
asking the Court “to reconsider its judgment dismissing” plaintiff’s claims for a lack
of personal jurisdiction.9 Plaintiff alleges that after the Court dismissed this case in
November 2025, defendant Woods made two subsequent appearances in New Orleans
“for the marketing, publication and exploitation of the infringing work.”10 According
to plaintiff, these appearances, in addition to three others that occurred in 2025,11 are
sufficient to establish personal jurisdiction over Woods.12
5 R. Doc. No. 27, at 2–5.
6 Id.
7 Id. at 23–24.
8 Id. at 6, 10, 13–15, 18.
9 R. Doc. No. 29.
10 R. Doc. No. 29-1, at 3.
11 The Court already considered these three prior appearances in its November 2025
order. See R. Doc. No. 27, at 12–18.
12 R. Doc. No 29-1, at 3–5.
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II. STANDARD OF LAW
The Federal Rules of Civil Procedure do not expressly recognize motions for
reconsideration. Bass v. U.S. Dep’t of Agric., 211 F.3d 959, 962 (5th Cir. 2000).
Accordingly, a motion for reconsideration filed within twenty-eight days of the district
court’s judgment is recharacterized as a motion to alter or amend the judgment and
it will be construed pursuant to Rule 59(e). See Fed. R. Civ. P. 59(e); Shepherd v. Int’l
Paper Co., 372 F.3d 326, 327 n.1 (5th Cir. 2004). A motion for reconsideration filed
more than twenty-eight days after the judgment is treated as a Rule 60(b) motion for
relief from judgment. See Shepherd, 372 F.3d at 327 n.1.
Plaintiff filed the present motion for reconsideration of judgment within
twenty-eight days of this Court’s November 2025 order.13 Accordingly, a Rule 59(e)
analysis is applicable. “Rule 59(e) ‘serve[s] the narrow purpose of allowing a party to
correct manifest errors of law or fact or to present newly discovered evidence.’”
Templet v. HydroChem Inc., 367 F.3d 473, 479 (5th Cir. 2004) (quoting Waltman v.
Int’l Paper Co., 875 F.2d 468, 473 (5th Cir. 1989)). A motion to alter or amend the
judgment under Rule 59(e) must establish (1) “an intervening change in the
controlling law”; (2) “newly discovered evidence that was previously unavailable”
exists; or (3) “a manifest error of law or fact.” Jennings v. Towers Watson, 11 F.4th
335, 345 (5th Cir. 2021) (citations omitted). Therefore, “[a] motion to alter or amend
the judgment under Rule 59(e) . . . cannot be used to raise arguments which could,
13 As noted, the Court issued its order and reasons in the above-captioned matter on
November 21, 2025. R. Doc. No. 27. Plaintiff filed her motion for reconsideration on
December 19, 2024. R. Doc. No. 29.
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and should, have been made before the judgment issued.” In re Life Partners
Holdings, Inc., 926 F.3d 103, 128 (5th Cir. 2019) (quoting Schiller v. Physicians Res.
Grp. Inc., 342 F.3d 563, 567 (5th Cir. 2003)). “Reconsideration of a judgment after its
entry is an extraordinary remedy that should be used sparingly.” Koerner v. CMR
Constr. & Roofing, L.L.C., 910 F.3d 221, 226 (5th Cir. 2018) (quoting Templet, 367
F.3d at 479).
III. ANALYSIS
The plaintiff contends that the Court should reconsider its November 2025
order granting the defendants’ motion to dismiss due to a lack of personal jurisdiction,
because since that order, defendant Woods “made two (2) additional appearances in
this forum for the marketing, publication and exploitation of the infringing work,” for
a total of “five (5) appearance in this district” in 2025.14
As an initial matter, plaintiff’s motion only presents arguments pertaining to
defendant Woods and does not advance any new allegations as to the other named
defendants. See generally R. Doc. No. 29-1 (only referring to new contacts with New
Orleans by Woods, without any reference to the other defendants). As such, the Court
will construe plaintiff’s motion to only concern reconsideration of personal
jurisdiction over defendant Woods. See Sayers Constr., L.L.C. v. Timberline Constr.,
Inc., 976 F.3d 570, 573 (5th Cir. 2020) (“[U]nilateral activity of a third party’ cannot
establish minimum contacts on behalf of a corporate defendant.” (quoting Walden v.
Fiore, 571 U.S. 277, 291 (2014))).
14 R. Doc. No. 29-1, at 3.
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According to plaintiff, the two additional appearances in New Orleans support
reconsideration because they sufficiently distinguish the present case from
Fernandez v. Jagger, No. 23-891, 2023 WL 6880431, at *3–5 (E.D. La. Oct. 18, 2023)
(Fallon, J.), aff’d 2024 WL 3717264 (5th Cir. Aug. 8, 2024), where the court found that
only “four appearances . . . over the course of several years” weighed against
establishing personal jurisdiction.15 Plaintiff argues that this new evidence presents
sufficient minimum contacts to establish “specific personal jurisdiction” over Woods.16
Defendants oppose plaintiff’s motion for reconsideration, primarily arguing
that the Court correctly found there was neither general nor specific jurisdiction over
any of the defendants and that, for purposes of reconsidering personal jurisdiction,
the Court may not consider facts “that arose after dismissal of the case.”17
Upon review, the Court agrees with defendants that Fifth Circuit authority
supports limiting the facts this Court may consider for purposes of personal
jurisdiction to the record as it existed, at the very least, prior to the November 21,
2025 dismissal. Courts in this circuit agree that there is some temporal limit on the
evidence a court may consider when deciding whether it has personal jurisdiction
15 Id. For avoidance of confusion, this Court notes that what was probative about the
four contacts in Fernandez and the contacts originally at issue in this case, for
purposes of a specific jurisdiction analysis, was not the quantity but the quality of
contacts, see R. Doc. No. 28, at 15–16. “Even a single, substantial act directed toward
the forum can support specific jurisdiction.” Asarco, Inc. v. Glenara, Ltd., 912 F.2d
784, 786 (5th Cir. 1990) (quoting Dalton v. R & W Marine, Inc., 897 F.2d 1359, 1361–
62 (5th Cir. 1990)).
16 Id. at 3–5.
17 R. Doc. No. 30, at 2, 9 (citing Asarco, Inc., 912 F.2d at 787 n.1; NavSav Holdings,
LLC v. Beber, 724 F. Supp. 3d 615, 623 (E.D. Tex. 2024); Diebold Election Sys., Inc.
v. AI Tech., Inc., 562 F. Supp. 2d 866, 872 (E.D. Tex. 2008)).
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over a party. See, e.g., Glazier Grp., Inc. v. Mandalay Corp., No. 06-2752, 2007 WL
2021762, *8 (S.D. Tex. July 11, 2007) (Rosenthal, J) (finding that courts may consider
events up until the filing of the complaint); Praetorian Specialty Ins. Co. v. Auguillard
Const. Co., Inc., 829 F. Supp. 2d 456, 467–68 (W.D. La. 2010) (Stagg, J) (reasoning
that courts may consider events up until the service of process or a waiver of service
is filed for specific jurisdiction).
Courts in this circuit agree that the temporal limit for general jurisdiction is
the time at which the complaint is filed, but there is apparently a disagreement
regarding whether Asarco, Inc. v. Glenara, Ltd., 912 F.2d 784, 781 n.1 (5th Cir. 1990),
established precedent that “the relevant time for determining jurisdiction is the filing
of the complaint,” for both general and specific personal jurisdiction. Compare Glazier
Grp., Inc., 2007 WL 2021762, at *8 (reasoning that “[c]ourts in the Fifth Circuit follow
the same approach in [general and] specific jurisdiction cases, looking to facts up to
the filing of the complaint rather than [post-complaint] conduct”), with Praetorian
Specialty Ins. Co., 829 F. Supp. 2d at 467–68 (finding the temporal limit in Asarco
Inc. only applies to general jurisdiction).18 Praetorian Specialty Ins. Co. employed a
different cutoff for specific jurisdiction, reasoning that it “should be determined by
18 The weight of persuasive authority in the Fifth Circuit favors applying the
temporal limit outlined in Asarco Inc., Glazier Grp. Inc., and their progeny, to both
general and specific jurisdiction. See, e.g., NavSav Holdings LLC, 724 F. Supp. 3d at
623; Diebold Election Sys., Inc., 562 F. Supp. 2d at 872; Healix Infusion Therapy, Inc.
v. Healix Health Prods., LLC, No. 08-1745, 2008 WL 11390840, *7 (S.D. Tex. July 31,
2008); Mgmt. Insights, Inc. v. CIC Enters., Inc., 194 F. Supp. 2d 520, 525 (N.D. Tex.
2001).
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examining the conduct of the defendant leading up to . . . the physical manifestation
of service of process or . . . the filing of a waiver of service.” Id.
With respect to the present motion, the outcome is the same regardless of
whether the Court limits its review to events prior to the filing of the complaint on
June 18, 2025,19 or up until defendant Woods waived service on July 14, 2025.20 The
new events that plaintiff points to in support of her motion, two performances in New
Orleans that allegedly both occurred on November 29, 2025,21 sit outside even the
latter cutoff date for this Court’s consideration.
Accordingly, except for facts that this Court deems irrelevant for a personal
jurisdiction analysis, plaintiff has not alleged any “change in the controlling law,”
“newly discovered evidence,” or “manifest error of law or fact,” to suggest this Court
has personal jurisdiction over Woods, or any other defendants. Therefore, plaintiff
has failed to provide the Court with any justification pursuant to Rule 59(e) to alter
or amend its previous order dismissing her claims for a lack of personal jurisdiction.
19 R. Doc. No. 1.
20 R. Doc. No. 13.
21 R. Doc. No. 29-1, at 3.
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IV. CONCLUSION
For the foregoing reasons,
IT IS ORDERED that plaintiff’s motion for reconsideration is DENIED.
New Orleans, Louisiana, February 25, 2026.
_______________________________________
LANCE M. AFRICK
UNITED STATES DISTRICT JUDGE
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