Learn About the Law
Get help with your legal needs
FindLaw’s Learn About the Law features thousands of informational articles to help you understand your options. And if you’re ready to hire an attorney, find one in your area who can help.
Julia DIXON v. Ning JIANG & another.1
MEMORANDUM AND ORDER PURSUANT TO RULE 23.0
The plaintiff, Julia Dixon, appeals from the dismissal of her complaint in Superior Court against the defendants, Ning Jiang and Yunping Wang. Although the complaint is not included in the record, Dixon asserts in her brief that the defendants owe her $70,000 for food, shelter, private school tuition, and more. According to the Superior Court docket, the defendants moved to dismiss all counts of Dixon's complaint for lack of personal jurisdiction pursuant to Mass. R. Civ. P. 12 (b) (2), 365 Mass. 754 (1974). The judge allowed the motion, concluding that “[e]ven taking a generous view of the circumstances asserted by [p]laintiff, there are individually and collectively insufficient contacts between [the defendants] and the Commonwealth to satisfy due process and the Commonwealth's long arm statute.”
On appeal, Dixon argues that the Superior Court has personal jurisdiction and that the defendants breached their contracts with her. Although we normally review the issue of personal jurisdiction de novo, Sullivan v. Smith, 90 Mass. App. Ct. 743, 746-747 (2016), meaningful review is not possible on the record before us. Dixon has not provided this court with a copy of her complaint, the defendants’ motion to dismiss, or a transcript of the motion hearing. The record appendix submitted by Dixon contains only emails between the parties, photocopies of bank checks paid to Dixon, and a 2017 memorandum of decision on a default judgment entered by a different judge in a different case.
To allow for meaningful review of a judge's ruling, the appellant must provide a record that is sufficient to support her claims on appeal. Arch Med. Assocs., Inc. v. Bartlett Health Enters., Inc., 32 Mass. App. Ct. 404, 406 (1992). See Mass. R. A. P. 18 (a), as appearing in, 481 Mass. 1637 (2019). “[The] appellant's obligation to include those parts of the trial transcript and copies of motions ‘which are essential for review of the issues raised on appeal ․ is a fundamental and long-standing rule of appellate civil practice’ ” (citation omitted). Cameron v. Carelli, 39 Mass. App. Ct. 81, 84 (1995). “Pro se litigants are held to the same standards as practicing members of the bar.” Commonwealth v. Jackson, 419 Mass. 716, 719 (1995). See Davis v. Tabachnick, 425 Mass. 1010, 1010 (1997) (pro se appellants held to same standards as litigants represented by counsel). Because we cannot discern any error from the record provided by Dixon, we must affirm the order allowing the defendants’ motion to dismiss for lack of personal jurisdiction.
Judgment affirmed.
Thank you for your feedback!
As the largest network of trusted legal brands, we help firms build authority across the platforms consumers and AI systems rely on most. Our network helps attorneys strengthen visibility, credibility, and preference where legal decisions begin.
Docket No: 24-P-278
Decided: March 14, 2025
Court: Appeals Court of Massachusetts.
Search our directory by legal issue
Enter information in one or both fields (Required)
Harness the power of our directory with your own profile. Select the button below to sign up.
Learn more about FindLaw’s newsletters, including our terms of use and privacy policy.
Get help with your legal needs
FindLaw’s Learn About the Law features thousands of informational articles to help you understand your options. And if you’re ready to hire an attorney, find one in your area who can help.
Search our directory by legal issue
Enter information in one or both fields (Required)