Brief Fact Summary. Appellee separated from appellant and moved to California. After their children joined her in California, appellee attempted to bring a divorce suit in California against appellant, who still resided in New York.
Synopsis of Rule of Law. In order to establish personal jurisdiction a defendant must have certain minimum contacts with the forum State so as not to offend traditional notions of fair play and substantial justice.
An essential criterion in all cases is whether the quality and nature of the defendant's activity is such that it is reasonable and fair to require him to conduct his defense in that State.View Full Point of Law
Issue. Did appellant have sufficient minimum contacts with California to allow California to assert personal jurisdiction over him in this matter?
Held. Appellant’s act of permitting his daughter to spend more time in California did not amount to his purposefully availing himself of the benefits and protections of California’s laws so as to permit California to assert personal jurisdiction.
The California Supreme Court found that personal jurisdiction may be exercised when a nonresident defendant caused an effect in that State and jurisdiction over causes arising from that effect is reasonable. It found that appellant had purposefully availed himself of the protections and laws of California by sending his daughter to live there with her mother.
The Due Process Clause operates as a limitation on the jurisdiction of state courts over nonresident defendants. In order to exercise such jurisdiction certain minimum contacts must be established so as to not offend traditional notions of fair play and substantial justice.
In reaching its decision the Court did not rely on the appellant’s glancing presence in the State or his marriage there, nor could it have. It did not rely on the fact that at separation appellant ha agreed to allow his children to live in California 3 months per year because it would discourage parents from entering into reasonable visitation agreements and it could arbitrarily subject one parent to suit in any State the other parent chose to spend time while having custody.
The purposeful act of allowing his daughter to spend more time in California than required under the agreement is insufficient to show that he purposefully availed himself of the benefits and protections of its laws. California’s assertion of personal jurisdiction was unreasonable in that it involved an agreement entered into with virtually no connection to the forum State.
Basic considerations of fairness favor appellant’s State of domicile as the proper forum. It was the State of the marital domicile where his entire family resided prior to the separation. The single act of allowing his daughter to spend more time in California is not one that a reasonable parent would expect to result in the substantial financial burden and personal strain of litigation in a forum 3,000 miles away. Jurisdiction in such cases would impose an unreasonable burden on family relations.
Discussion. The Court found that the single act of permitting his daughter to spend more time in California than required under a separation agreement was insufficient to establish the minimum contacts with California such that it would not offend traditional notions of fair play and substantial justice to assert personal jurisdiction over appellant.