Statutory Limits on Personal Jurisdiction

Be careful, however, not to conclude that every assertion of jurisdiction under a long-arm statute is automatically constitutional simply because the statute purports to authorize it. In the area of personal jurisdiction, it is not always easy to tell what is and is not constitutional. Consequently, the reach of a state’s long-arm statute may sometimes exceed its constitutional grasp. Suppose, for example, that an Iowa long-arm statute authorized its courts to take jurisdiction in all cases brought by resident plaintiffs. It would certainly be unconstitutional to apply such a statute to a case in which the Iowa plaintiff purchased goods from a Colorado defendant in Colorado. Assuming that the defendant has no other contacts with Iowa, there would be no constitutional authority to assert personal jurisdiction over the defendant, since the claim does not arise out of any minimum contacts with Iowa. This case falls within the “bulge” area in Figure 2-3, in which the statute authorizes jurisdiction (because the plaintiff is a resident), but it would exceed the limits of due process to exercise that jurisdiction.

Figure 2-2.

However, the statute could be applied in other cases without violating due process. For example, if the case arose from a sale by the defendant to the plaintiff that took place in Iowa, the exercise of jurisdiction would be constitutionally permissible because the defendant’s voluntary contacts with Iowa gave rise to the claim. This case would fall in the shaded area on the diagram.

In such cases, where the statute may be constitutional as applied to some cases but not all, the courts do not invalidate the statute entirely; they simply refuse to apply it to cases that fall outside the bounds of due process. Consequently, the statute remains in force and may be applied in other cases that are within due process limits.

All long-arm statutes that base personal jurisdiction on specific enumerated acts require that the claim sued upon arise out of the act itself. See, e.g., Uniform Interstate and International Procedure Act §1.03(b), infra p. 33. This limitation is rooted in the International Shoe analysis, which holds that limited in-state contacts only support jurisdiction over claims that arise from those contacts. See the “Shoe spectrum” at p. 6. By echoing that limitation in the long-arm statute itself, the legislature ensures that the statute will not be used to reach cases beyond the constitutional bounds of due process.

Figure 2-3.