Legal Memorandum: Specific Personal Jurisdiction

Issue: Under the laws of the federal courts, when may specific personal jurisdiction be asserted?

Area of Law: Litigation & Procedure
Keywords: Specific personal jurisdiction; Threshold
Jurisdiction: Federal
Cited Cases: None
Cited Statutes: None
Date: 03/01/2008

Personal jurisdiction may be general or specific.  When the plaintiff’s claim arises from the defendant’s contacts with the forum state, specific personal jurisdiction is established by a showing that those contacts meet a minimum threshold.  Ultimate Res., Inc. v. Goss, No. 99-1826, 2000 U.S. Dist. LEXIS 3154 (E.D. Pa. Mar. 17, 2000).  While the threshold generally is not established solely on the basis of a contract with a resident plaintiff, “not much more is required.”  Id. (finding personal jurisdiction appropriate over individual defendants who were presidents of their respective corporations because they had repeated contact with the plaintiff corporation “and received significant benefits from” the plaintiff).  See also Gerald Chamales Corp. v. Oki Data Americas, Inc., 557 F. Supp. 2d 494, 499-500 (D.N.J. 2008) (finding that exercise of personal jurisdiction over the nonresident corporate chairperson was proper, given that he traveled to the forum state to discuss sale of corporation, and engaged in correspondence by telephone and email on numerous occasions with persons in forum state; and because contractual provisions should have put him on notice that he could reasonably anticipate being brought into court there); Christ v. Cormick, C.A. No. 06-275-GMS,  2007 U.S. Dist. LEXIS 49825 (D. Del. Jul. 10, 2007) (finding that exercise of personal jurisdiction was proper over defendant who was the sole initial member of limited liability company and the only person capable of managing the company’s affairs, especially given that he purposefully availed himself of the privilege to conduct affairs in forum state).


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