Also known as: minimum contact · min contacts
Written by attorneys · grounded in primary & secondary sources — see below
A defendant's connections with the forum state, such as business activity or actions foreseeably leading to business activity, that are substantial enough to permit the forum state's courts to exercise personal jurisdiction over the defendant without offending traditional notions of fair play and substantial justice.
A Delaware trustee received a trust corpus from a Florida settlor who later moved to Florida. When Florida heirs challenged the trust, the trustee argued lack of contacts. The court held that the trustee had not purposefully availed itself of Florida law, so minimum contacts were absent.
An out-of-state shoe company employed salesmen who resided in Washington and continuously solicited orders there. When Washington assessed unemployment taxes, the company objected to jurisdiction. The Court found the systematic sales activity created minimum contacts supporting jurisdiction.
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Maria Morales owned shares in a Delaware corporation but lived in Arizona. A plaintiff attached the shares in Delaware to secure a judgment on an unrelated claim. The court held that the mere presence of the shares did not create minimum contacts when the dispute bore no relation to the property.
Monica Morgan was served with process while attending a conference in California. The plaintiff sued Morgan over events that occurred entirely in New York. The court upheld jurisdiction on the basis of in-state service even though the claim was unrelated to the visit.
Maya Malik lived with her children in California for several years before moving to New York. Her former spouse remained in California and sought increased support. The court found that Malik's prior residence with the children supported jurisdiction over the support claim.
Monarch Pharmaceuticals, an out-of-state corporation, appointed an agent for service in Ohio to obtain a limitations defense. When sued on an unrelated claim, the company argued the appointment did not create jurisdiction. The court addressed whether the appointment subjected the company to general jurisdiction in Ohio.
The defendant must purposefully avail itself of the privilege of conducting activities in the forum state. Unilateral activity by the plaintiff or a third party cannot satisfy the requirement.
Supporting sources
No. When the claim is unrelated to the property, its mere presence in the forum does not create the required contacts for either in personam or quasi in rem jurisdiction.
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Minimum contacts analysis supports specific jurisdiction when the claim arises out of the contacts. General jurisdiction requires continuous and systematic contacts that render the defendant at home in the forum regardless of claim relatedness.
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Repeated, targeted communications directed at a forum resident over an extended period can establish purposeful availment when they give rise to the claim, even without physical presence.
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…