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Brief Fact Summary.
MoneyMutual operated website that matched individuals with lenders for short term “payday loans.” Respondents, Minnesota residents, filed a class action complaint in Minnesota state court against MoneyMutual alleging that MoneyMutual engaged in illegal and tortious conduct in connection with its loan business. MoneyMutual moved to dismiss the complaint for lack of personal jurisdiction. The district court upheld jurisdiction and the appellate court affirmed.
Synopsis of Rule of Law.
E-mail based contacts with a forum can provide a basis for personal jurisdiction if the sender knew or should have known that the recipient was located in a particular forum and would receive the email there.
A court may assert specific jurisdiction, jurisdiction over cases involving the defendant's contacts with the forum state, if the defendant has purposefully directed his activities at residents of the forum and the litigation results from alleged injuries that arise out of or relate to those activities.
View Full Point of Law
Four Minnesota residents filed a class action complaint against MoneyMutual, the operator of a website that matched individuals with lenders for short term “payday loans.” Respondents alleged that MoneyMutual engaged in illegal and tortious conduct in connection with its loan business because: the terms of the loans were illegal under state law, MoneyMutual matched applicants with unlicensed lenders, and the website’s advertising contained misrepresentations that violated state law. MoneyMutual moved to dismiss the complaint for lack of personal jurisdiction. The district court upheld jurisdiction and the appellate court affirmed.
Issue.
Did the lower courts err in upholding personal jurisdiction over MoneyMutual in Minnesota?
Held.
No. Jurisdiction was properly exercised over MoneyMutual, based on its commercial solicitations within Minnesota.
Discussion.
Traditional minimum contacts analysis considers the quantity, nature, and quality of contacts, and whether they establish the defendant’s substantial connection with and purposeful availing of a forum. Here: