Also known as: state courts jurisdiction · state-court jurisdiction · state jurisdiction · jurisdiction of state courts
Written by attorneys — see sources below.
A state tribunal's authority to adjudicate disputes involving particular parties or property within its territorial boundaries. The Due Process Clause limits this power by requiring that the defendant possess minimum contacts with the forum such that the exercise of jurisdiction does not offend traditional notions of fair play and substantial justice.
Vanessa, a State C resident, sued Dr. Queen in State B after surgery performed entirely in State A. She attached Queen's vacation condominium in State B, which Queen used only for occasional personal trips and on which she paid taxes. The malpractice claim bore no relation to the property. The State B court lacked personal jurisdiction because the bare presence of unrelated property cannot satisfy minimum contacts.
Lulu McGee, a California resident, purchased life insurance from a Texas company that later refused to pay after her husband's death. The company had no other contacts with California. The California court properly exercised jurisdiction because the contract had a substantial connection with the forum and the claim arose directly from that contact.
In 1944, Lowell Franklin, a resident of California, purchased a life insurance policy from the Empire Mutual Insurance Company, an Arizona corporation. In 1948, the respondent International Life Insurance Company agreed with Empire Mutual to assume its insurance obligations. Respondent then mailed a reinsurance certificate to Franklin in California offering to insure him in accordance with the terms of the policy he held with Empire Mutual. He accepted this offer and from that time until his death in 1950 paid premiums by mail from his California home to respondent’s Texas office. Petitioner Lulu B. McGee, Franklin’s mother and the beneficiary under the policy, sent proofs of his death to the respondent, but it refused to pay, claiming that he had committed suicide. It appears that neither Empire Mutual nor respondent has ever had any office or agent in California, and respondent has never solicited or done any insurance business in California apart from the policy involved here. The California statute subjecting foreign corporations to suit on insurance contracts with residents became law in 1949, after respondent had entered into the agreement with Franklin. Petitioner recovered a judgment in a California state court against respondent on the contract of insurance, with service of process by registered mail at respondent’s principal place of business in Texas pursuant to the state statute. Unable to collect the judgment in California, petitioner filed suit on the judgment in a Texas court. The Texas courts refused to enforce the judgment, holding it void under the Fourteenth Amendment because service of process outside California could not give the courts of that State jurisdiction over respondent. The Supreme Court granted certiorari to review the case.
View caseA New York mother sought increased child support from her former husband, a California resident who had never visited New York. The couple's children lived in New York with the mother. The New York court could not exercise jurisdiction because the father's only contacts were the original divorce decree and occasional payments, which were insufficient to support specific jurisdiction over the new claim.
Ezra Kulko married Sharon Kulko Horn in 1959 during a three-day stopover in California while en route from a military base in Texas to Korea. Both parties were New York domiciliaries who returned to New York after the marriage and Ezra's service. Their children Darwin and Ilsa were born in New York in 1961 and 1962. The family lived together in New York City until their separation in March 1972. Following the separation, Sharon moved to San Francisco, California. In September 1972, Sharon flew to New York to sign a separation agreement providing that the children would spend school years with their father and vacations with their mother in exchange for $3,000 annual child support payments during her custody periods. Sharon obtained a Haitian divorce incorporating the agreement and returned to California, where she remarried. The children resided with their father during the school year until December 1973, when Ilsa remained in California after her father bought her a one-way ticket. In January 1976 Darwin flew to California using a ticket sent by his mother. Less than one month after Darwin's arrival, Sharon commenced an action in California Superior Court to establish the Haitian divorce decree as a California judgment, modify it to award her full custody, and increase the father's child-support obligations. Ezra appeared specially and moved to quash service on the ground that he lacked sufficient minimum contacts with California. The trial court denied the motion. The Court of Appeal affirmed. The California Supreme Court sustained the rulings in a 4-2 decision before Ezra appealed to the United States Supreme Court.
View caseA California plaintiff injured by a motorcycle tire valve sued the Japanese valve manufacturer in California. The manufacturer sold valves to a Taiwanese assembler that placed finished motorcycles into the United States stream of commerce. The California court lacked jurisdiction because the manufacturer had not purposefully directed its product toward California or established minimum contacts there.
In September 1978 Gary Zurcher lost control of his Honda motorcycle on Interstate Highway 80 in Solano County, California, and collided with a tractor. Zurcher suffered severe injuries while his passenger and wife Ruth Ann Moreno was killed. In September 1979 Zurcher filed a product liability action in the Superior Court of California for Solano County against Cheng Shin Rubber Industrial Co., Ltd., the Taiwanese manufacturer of the motorcycle tube, and other defendants. Zurcher alleged that defects in the tire, tube, and sealant caused the accident. Cheng Shin filed a cross-complaint seeking indemnification from Asahi Metal Industry Co., Ltd., the Japanese manufacturer of the tube’s valve assembly. Zurcher’s claims against Cheng Shin and the other defendants were eventually settled and dismissed, leaving only Cheng Shin’s indemnity action against Asahi. Asahi is a Japanese corporation. It manufactures tire valve assemblies in Japan and sells them to Cheng Shin and other tire manufacturers for use as components in finished tire tubes, with all sales to Cheng Shin taking place in Taiwan. Asahi sold Cheng Shin 150,000 valve assemblies in 1978, 500,000 in 1979, 500,000 in 1980, 100,000 in 1981, and 100,000 in 1982. Those sales accounted for 1.24 percent of Asahi’s income in 1981 and 0.44 percent in 1982. Cheng Shin alleged that approximately 20 percent of its United States sales occur in California. In 1983 an attorney for Cheng Shin examined valve stems at one cycle store in Solano County and found that of 115 tire tubes, 12 Asahi-marked valve stems were incorporated into Cheng Shin tubes. An affidavit from a Cheng Shin manager stated that discussions with Asahi had covered worldwide sales including the United States. Asahi’s president stated the company never contemplated that its limited sales would subject it to lawsuits in California. The Superior Court denied Asahi’s motion to quash service of summons. The Court of Appeal issued a peremptory writ commanding the Superior Court to quash service. The California Supreme Court reversed. The United States Supreme Court granted certiorari.
View caseA New Jersey plaintiff served a California defendant with process while the defendant was briefly visiting California on business. The underlying claim arose from events that occurred years earlier in New Jersey. The California court could exercise jurisdiction because the defendant's voluntary presence in the forum at the time of service supplied the necessary contacts under traditional rules.
Dennis Burnham married Francie Burnham in 1976 in West Virginia. In 1977 the couple moved to New Jersey, where their two children were born. In July 1987 the Burnhams separated. Mrs. Burnham, who intended to move to California, was visiting her parents in that State when she filed for divorce in New Jersey on grounds of extreme cruelty, seeking spousal and child support, custody of the children, and possession of the family home. In early August 1987 petitioner visited Mrs. Burnham in California to discuss the children and the separation. He took the children to San Francisco for a few days. Upon returning the children to Mrs. Burnham, petitioner was served with a summons and complaint for divorce filed in California Superior Court that also sought custody of the children. After being served, petitioner returned to New Jersey. In January 1988 petitioner made a special appearance in the California action and moved to quash service of process on the ground that the court lacked personal jurisdiction over him. The Superior Court denied the motion, and the State Court of Appeal affirmed. The California Supreme Court denied review. The United States Supreme Court granted certiorari to resolve a conflict among the state and federal courts.
View caseA plaintiff filed a federal civil rights claim in state court against city police officers who allegedly violated his constitutional rights during an arrest. The officers moved to dismiss, arguing that only federal courts could hear the claim. The state court properly retained jurisdiction because nothing in the statute creating the cause of action divested state tribunals of concurrent authority over federal claims.
On October 29, 1958, at approximately 5:45 a.m., thirteen Chicago police officers entered the apartment of James Monroe and his family without a search warrant or arrest warrant. The officers roused the Monroes from bed using flashlights and forced them at gunpoint to stand naked in the living room while ransacking every room, emptying drawers, and ripping mattress covers. Detective Pape struck Mr. Monroe several times with his flashlight and called him "nigger" and "black boy." Other officers hit and kicked several of the children and pushed them to the floor. Mr. Monroe was then taken to the police station and detained on open charges for ten hours. During this period he was interrogated about a murder, exhibited in lineups, and not permitted to call his family or attorney, although he was not brought before a magistrate despite their availability. He was released without any criminal charges being filed against him. The complaint alleged that these actions occurred under color of the statutes, ordinances, regulations, customs, and usages of Illinois and Chicago, and that the City had no rules or controls over its police officers, permitting them to act without restraint. The Monroes claimed deprivations of rights under the Fourth and Fourteenth Amendments and sought compensatory and punitive damages from the officers and the City. The district court dismissed the complaint for failure to state a claim upon which relief could be granted. The Court of Appeals for the Seventh Circuit affirmed the dismissal, and the Supreme Court granted certiorari to review the judgment.
View caseNo. When the claim does not arise from the property, its mere presence in the state supplies no minimum contacts and cannot support personal jurisdiction under the Due Process Clause.
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A single contract with a forum resident that has a substantial connection to the claim can support specific jurisdiction, even if the insurer has no other presence in the state.
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Only if the parent has purposefully availed himself of the forum in a manner related to the support obligation. Sporadic payments or an old divorce decree alone are ordinarily insufficient.
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