Also known as: significant contact · significant contacts · significant aggregation of contacts · aggregation of contacts
Written by attorneys · grounded in primary & secondary sources — see below
A constitutional standard requiring that a state possess a significant contact or significant aggregation of contacts with a dispute that creates state interests. Application of the state's law must not be arbitrary or fundamentally unfair.
AutoTech Components maintains its main plant in the Eastern District but operates a research facility and test track in the Western District of the same state. An injured driver sues in the Western District federal court. The court treats the Western District as a separate state and finds AutoTech's research and testing contacts sufficient to support personal jurisdiction there, making venue proper under the residence prong.
Phillips Petroleum faces a class action from royalty owners in multiple states over oil and gas leases. Kansas has only a modest number of leases but applies its own law to the entire class. The Supreme Court upholds the choice because Kansas's contacts with the defendant and the leases create state interests that render application of its law neither arbitrary nor fundamentally unfair.
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A family injured in Oklahoma by a defective car purchased in New York sues the regional distributor in Oklahoma. The distributor's only contacts with Oklahoma are the single sale and the car's presence after the accident. The Supreme Court holds these contacts too attenuated for the state to possess the significant aggregation of contacts needed to create interests supporting application of its law.
Helicopteros Nacionales, a Colombian company, purchases helicopters and parts from Texas suppliers and sends pilots for training in Texas. Survivors of a crash in Peru sue in Texas. The Supreme Court finds the purchases and training visits insufficient to create the continuous and systematic contacts needed for general jurisdiction over an unrelated claim.
Allstate Insurance faces a claim arising from a Wisconsin accident involving a Minnesota decedent. Minnesota applies its own stacking rule after the insured's estate moves there post-accident. The Supreme Court holds that Minnesota's contacts, including the decedent's prior employment and the insurer's presence in the state, create sufficient state interests to permit application of Minnesota law.
New York parents sue the Boy Scouts after their son is abused on a New Jersey camping trip. New Jersey law would bar the claim while New York law would permit it. The New York Court of Appeals applies New Jersey law because New Jersey has the most significant contacts with the tort and the parties' relationship, making application of its law neither arbitrary nor unfair.
The state must possess either a single significant contact or an aggregation of contacts that together are significant. Those contacts must also create state interests such that applying the state's law is neither arbitrary nor fundamentally unfair.
Each district is treated as if it were a separate state. The corporation resides for venue purposes in any district whose contacts would support personal jurisdiction if that district stood alone, or, if none qualify, in the district of its most significant contacts.
No. Bare presence of property unrelated to the claim does not create the purposeful contacts needed. The property must be accompanied by additional ties that make jurisdiction or choice of law fair under due process standards.
…forum. McGee, supra . Because lesser burdens reduce the unfairness to the defendant, jurisdiction may be justified despite less significant contacts. The burden, of course, must be of constitutional dimension. Due process limits on jurisdiction do not protect a defendant from all inconvenience of travel, McGee, supra , at 224, and it…