Also known as: minimum contacts · minimum contacts doctrine
Written by attorneys · grounded in primary & secondary sources — see below
A constitutional standard that permits a state court to exercise personal jurisdiction over a nonresident defendant when the defendant has sufficient contacts with the forum such that the suit does not offend traditional notions of fair play and substantial justice. The contacts must reflect purposeful availment by the defendant of the forum's benefits and protections, and the claim must arise out of or relate to those contacts.
Matthew Martinez, a Florida resident, sued a Delaware trust company in Florida court over trust administration issues. The trust company had no office in Florida, conducted no business there, and held no trust assets in the state. The court dismissed the suit because the trust company's contacts with Florida were insufficient to support jurisdiction.
Musa Mensah, a consumer in State J, sued StyleWave, an out-of-state online retailer, in State J court for fraudulent advertising after receiving multiple shipments and seeing targeted promotions. StyleWave had shipped dozens of orders to State J residents over two years and tailored promotions to the state. The court denied the motion to dismiss because those repeated commercial activities created the required contacts.
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Michelle Murphy, a Delaware shareholder, sought to attach shares of a nonresident defendant in a Delaware court to compel appearance in an unrelated derivative suit. The shares were the defendant's only connection to Delaware. The court held that the mere presence of property in the forum, without any relation to the claim, did not establish sufficient contacts for jurisdiction.
Miles Montgomery, a California motorcyclist injured in a crash, sued a Japanese valve manufacturer in California court. The manufacturer had sold valves to a Taiwanese tire company knowing some would reach California but had not directly marketed or sold in the state. The court found the indirect awareness of eventual sales insufficient to create the necessary contacts for jurisdiction.
Mina Mehta, a North Carolina resident whose son died in a bus accident, sued foreign tire manufacturers in North Carolina court. The manufacturers had placed tires into the national distribution network but maintained no direct sales, advertising, or offices in the state. The court held that those attenuated connections did not satisfy the minimum contacts requirement for the claim.
Mustafa Mahmoud, a Minnesota resident injured in a Wisconsin accident, sued an out-of-state defendant in Minnesota court. The defendant had conducted unrelated business in Minnesota but the claim arose entirely from Wisconsin events. The court held that those unrelated contacts did not satisfy the minimum contacts requirement for jurisdiction.
The defendant must purposefully avail itself of the privilege of conducting activities within the forum state, thereby invoking the benefits and protections of its laws. Unilateral activity by the plaintiff or a third party cannot satisfy this requirement.
Supporting sources
No. The Due Process Clause permits jurisdiction when the defendant has such minimum contacts with the forum that maintaining the suit does not offend traditional notions of fair play and substantial justice. The focus is on contacts, relatedness, and fairness rather than strict territorial power.
Supporting sources
No. The minimum contacts standard applies to all exercises of state-court jurisdiction, including quasi in rem actions. The mere presence of a defendant's property in the forum, when the dispute is unrelated to that property, does not by itself establish sufficient contacts.
Supporting sources
Specific jurisdiction is claim-specific. A state court may exercise jurisdiction over a defendant only when each plaintiff's claim arises out of or relates to the defendant's contacts with the forum. Similar claims by resident plaintiffs do not create jurisdiction over unrelated claims by nonresidents.
Supporting sources
…to subject a defendant to a judgment in personam , if he be not present within the territory of the forum, he have certain minimum contacts with it such that the maintenance of the suit does not offend “traditional notions of fair play and substantial justice.” Milliken v. Meyer , 311 U. S. 457, 463. See Holmes, J., in…