Also known as: minimum contacts analysis · minimum contact analysis · minimum-contacts test · minimum contacts
Written by attorneys · grounded in primary & secondary sources — see below
A constitutional inquiry into whether a nonresident defendant has sufficient connections with the forum state to permit the exercise of personal jurisdiction consistent with due process. The analysis examines purposeful availment of the forum's benefits and protections, the relation of the claim to those contacts, and the reasonableness of jurisdiction under traditional notions of fair play and substantial justice.
Oceanic Lines, a foreign shipping company, had no offices or operations in State FF1. Lisa, a broker in State EE1, sued Oceanic in State FF1 after it failed to pay commissions on voyages that never touched FF1 ports. Oceanic's only link to FF1 was an older vessel docked there for unrelated repairs. The court dismissed the action because the vessel's presence supplied no purposeful contacts tied to the brokerage claim.
Silver Clinical, a Swiss supplier, sold ingredients to a French firm that later distributed tablets in a mid-Atlantic state. Patients injured by the tablets prompted an indemnity suit against Silver Clinical in that state's court. Silver Clinical had placed the ingredients into international commerce without directing them specifically to the forum. The court granted dismissal because mere awareness of downstream distribution did not create the required contacts.
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Harborway Brokers obtained a state court order arresting an Oceanic vessel docked in State FF1 for repairs. The underlying claim involved unpaid commissions on foreign voyages that never involved FF1. Oceanic had no other ties to the state. The court held that the vessel's unrelated presence could not support jurisdiction over the commission dispute.
King, a New York attorney, was served with a Colorado malpractice complaint while on a layover at Denver airport. The underlying claim arose entirely from litigation in Arizona. King had no other Colorado connections. The court upheld jurisdiction based on physical presence at the time of service.
Asahi, a Japanese valve manufacturer, sold components to a Taiwanese firm that incorporated them into motorcycles distributed in California. A California rider was injured when a tire failed. Asahi had no direct sales, advertising, or agents in California. The court found that awareness of possible forum distribution alone did not establish minimum contacts.
Pamela sought to register a support judgment in State K against the child's father after the family had left the state. The father was served while attending a training seminar in State K but had no ongoing residence or business there. The court declined enforcement because the father's isolated visit did not create purposeful contacts supporting jurisdiction over the support claim.
No. The minimum contacts standard applies to quasi in rem actions. Property presence alone supplies no contacts when the dispute does not arise from or relate to the property.
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No. A foreign defendant must purposefully direct activities toward the forum rather than merely place goods into commerce with knowledge they might arrive there. Additional targeting evidence is required.
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Yes when the contacts are repeated, directed specifically at the forum plaintiff, and give rise to the claim. The volume and continuity of the dealings can create a substantial connection that makes litigation in the forum foreseeable.
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Yes. Transient jurisdiction permits service while the defendant is physically present regardless of contacts or claim relatedness. Physical presence at the moment of service supplies the constitutional basis.
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…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…