Choosing a Proper Court

RELATION OF THE CLAIM TO THE FORUM

Another understandable source of confusion in applying the three-ring analysis is the fact that one of the rings may require a relationship between the state in which the suit is brought and the claim the plaintiff asserts, while that relationship is irrelevant to applying the other rings. Suppose, for example, that Santini, a California high-wire artist, sues Robinson Shows, Inc., a Virginia corporation with its principal place of business in Virginia. If Santini sues Robinson Shows in an Alabama federal court for a negligence claim that arose in Missouri, it is irrelevant to diversity analysis that the claim did not arise in Alabama. Diversity jurisdiction turns on a comparison of the citizenship of the opposing parties, not on the relationship between the parties or the claim and the forum state. So long as the parties are from different states (and the amount-in-controversy requirement is met) diversity is satisfied.

Similarly, the fact that Santini’s claim did not arise in Alabama may be irrelevant to the venue and personal jurisdiction analysis. If the circus does sufficient business in Alabama, it may be subject to general in personam jurisdiction there. And, if that is true, venue will be proper in the Alabama district where the business activity takes place, under 28 U.S.C. §§1391(a)(1), (c), and (d), even though the claim does not arise out of the business done in that district. For example, if Robinson has its principal place of business in the Southern District of Alabama, that activity would support general in personam jurisdiction over Robinson, if the Southern District were a state, even though Santini’s claim did not arise there. This suffices to make that district a proper venue under §§1391(b)(1) and (d).

Because venue in cases against corporations is proper where the corporation is subject to personal jurisdiction, under §1391(c) or (d), it should follow that wherever a corporation is subject to personal jurisdiction will also be a proper venue. Not quite true, unfortunately. First, of course, it would not suffice that it was subject to personal jurisdiction on some other claim unrelated to the case before the court. Second, the combination of §§1391(b)(1) and (d) authorizes venue only in the particular districts within a state where the defendant has contacts. So a corporate defendant may be subject to personal jurisdiction in a state, but some districts in that state may still be improper venues. In Santini’s case, for example, the Northern District of Alabama would not be a proper venue, if Robinson Shows has no contacts in that district, even though it is subject to personal jurisdiction anywhere in Alabama.[1]

The subtlety of these interrelations suggest that they were deliberately designed to intimidate first-year law students. However, the situation is not really so bad once you have worked with the related doctrines in the context of specific facts. The following examples will help you sort out the various rings. Assume, unless the example specifies otherwise, that the relevant long-arm statute is like California’s (see supra, p. 28), which authorizes the exercise of all constitutionally permissible jurisdiction, and that all suits are brought in federal court.