Also known as: sufficiently nexus · nexus requirement · minimum contacts
Written by attorneys · grounded in primary & secondary sources — see below
An adequate link between a defendant's purposeful contacts with a forum and a plaintiff's claim that permits a court to exercise specific personal jurisdiction consistent with due process. The link must arise from the defendant's own conduct directed at the forum rather than from the unilateral actions of the plaintiff or a third party.
Sophia Singh, a New York resident, mailed a trust document to a Florida trustee for execution. After the trustee died, Singh sued the Florida estate in New York. The trustee had never traveled to New York or directed any activity there. The court found no sufficient nexus because the trustee's contacts resulted solely from Singh's unilateral choice to send documents to Florida.
Seth Shapiro, a State J consumer, ordered clothing repeatedly from StyleWave, an out-of-state online retailer that shipped dozens of orders to State J and ran State J-specific promotions. Shapiro sued in State J for breach of warranty arising from those purchases. The court held that the repeated, targeted shipments and promotions supplied a sufficient nexus between StyleWave's forum contacts and Shapiro's claim.
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Simon Stern, a nonresident, owned shares in a Delaware corporation. A plaintiff sued Stern in Delaware to assert quasi in rem jurisdiction over an unrelated tort claim arising in another state. The shares were the only Delaware asset. The court ruled that the mere presence of the shares did not create a sufficient nexus to the claim, so jurisdiction failed.
Samantha Stone, a low-level federal employee, accepted honoraria for articles unrelated to her duties. The government sought to enforce a broad honoraria ban. The court examined whether a sufficient nexus existed between the speech and any demonstrated harm to government operations and found none, so the ban could not be applied to her.
The contact must be purposeful, created by the defendant, and directly related to the plaintiff's claim. Unilateral actions by the plaintiff or third parties do not count. The inquiry focuses on whether the defendant invoked the benefits and protections of the forum's laws in a way that makes jurisdiction fair.
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No. When the claim is unrelated to the property, its mere presence does not establish the required connection. The minimum contacts standard applies to quasi in rem actions just as it does to in personam actions.
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Each plaintiff's claim must independently arise out of or relate to the defendant's forum contacts. Similar claims by residents do not create jurisdiction over nonresidents whose injuries occurred entirely outside the forum with no forum-related connection.
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…judicial legislation also persuades us to reject the Government's second suggestion—that we modify the remedy by crafting a nexus requirement for the honoraria ban. We cannot be sure that our attempt to redraft the statute to limit its coverage to cases involving an undesirable nexus between the speaker's official duties and…