Also known as: minimum contacts standard · minimum contact standard · minimum-contacts test · minimum contacts test · minimum contacts doctrine
Written by attorneys · grounded in primary & secondary sources — see below
A constitutional standard requiring that a defendant have purposeful contacts with the forum state such that the exercise of jurisdiction does not offend traditional notions of fair play and substantial justice. The standard governs every form of state-court jurisdiction, including actions based on attachment of property unrelated to the claim.
Casey, a traveling nurse from State A, sued Meridian Health Systems in State B court for breach of an employment contract negotiated and performed only in State C. Meridian had no facilities or marketing in State B. Casey attached Meridian's investment account at a bank branch in State B to secure any judgment. The court granted Meridian's motion to dismiss because the account alone supplied no purposeful contacts tied to the claim.
Summit Lift Co., incorporated and headquartered in State E, sold a crane wholesale in State E to a regional distributor. The distributor resold and delivered the crane to a State F jobsite where it collapsed and injured worker Lopez. Summit had never done business or owned property in State F. The State F court granted Summit's motion to dismiss because the unilateral resale created no purposeful contacts by Summit with State F.
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Phillips Petroleum faced a class action in Kansas court brought by royalty owners, including many nonresidents whose leases lay outside Kansas. The company argued that absent class members lacked minimum contacts with Kansas. The court examined whether Kansas could bind those members without their purposeful availment of the forum.
A New York father sent his children to live with their mother in California under a custody agreement. The mother later sought increased child support in California court. The father had no purposeful contacts with California beyond the children's residence. The court held that California lacked jurisdiction over the father under the minimum-contacts standard.
No. After Shaffer, the mere presence of property unrelated to the claim does not satisfy the minimum-contacts standard. Every exercise of state-court jurisdiction, including quasi in rem actions based on attachment, must meet the purposeful-contacts test.
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Yes, when the contract is deliberately solicited and the claim arises directly from that relationship. A targeted solicitation followed by an ongoing contractual obligation tied to forum property satisfies purposeful availment for specific jurisdiction.
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No. Unilateral action by a distributor or purchaser cannot create the required purposeful availment. The defendant itself must direct conduct toward the forum market.
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The court must determine whether absent class members have minimum contacts with the forum or whether the forum may bind them without such contacts. The minimum-contacts inquiry remains central to personal jurisdiction over those members.
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…permit a state to exercise personal jurisdiction over a defendant with which the state has no contacts, ties, or relations. The minimum-contacts standard of International Shoe requires that a defendant have "purposefully availed itself of the privilege of conducting activities within the forum State." Hanson v. Denckla , 357 U.S. 235, 253…