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1. Pennoyer v. Neff (SCOTUS 1878)
Your casebook had better preface this classic case with Mitchell v. Neff or you're going to be really lost. Marcus Neff hired an attorney, John Mitchell, to help him purchase land in Oregon. Neff got the property but never paid Mitchell. Mitchell sued Neff, but Neff was nowhere to be found. Mitchell won a judgment and levied it against Neff's newly acquired land. Mitchell then assigned the case to Sylvester Pennoyer -- and finally we've arrived at the current case. (Though the story is much more interesting than this.) Neff wanted the judgment against him reversed because the property was never attached prior to the start of the litigation, meaning the court never had jurisdiction over it, or jurisdiction over him. The Supreme Court agreed and returned the property to Neff. Much of this case isn't relevant anymore, but it's a classic nonetheless.
2. International Shoe v. Washington (SCOTUS 1945)
The state of Washington levied a tax on businesses operating in the state. International Shoe was headquartered in Delaware and Missouri; it had only about a dozen salesmen in Washington. When Washington sued International Shoe over the unpaid taxes, the issue was whether Washington was the right forum. International Shoe established the modern standard of "sufficient minimum contacts" for personal jurisdiction. Because International Shoe conducted business in Washington, suing it there did not "offend traditional notions of fair play and substantial justice." Repeat that phrase kids, it's a classic in and of itself.
3. Gray v. American Radiator (Illinois Supreme Court 1961)
Poor Mrs. Gray was injured when her radiator exploded. She sued the radiator manufacturer and the manufacturer of one of the components. The court ruled that Titan Valve Company, an out- of-state corporation, could be sued in Illinois because it knew, and presumed, that there was a substantial chance its products would be incorporated into water heaters sold in Illinois.
4. World Wide Volkswagen v. Woodson (SCOTUS 1980)
The Woodsons bought a car at Seaway, a Volkswagen dealership in New York and were involved in a car accident in Oklahoma. They sued Seaway, the manufacturer, Volkswagen of America, and World Wide Volkswagen. Could Seaway, a New York dealership, really be dragged into court in Oklahoma? Here, the court brought a new concept to personal jurisdiction: "purposeful availment." The fact that Seaway sold cars, which could be driven anywhere, didn't mean that consented to being sued anywhere in the country. Because Seaway otherwise had nothing to do with Oklahoma, it wasn't foreseeable that it would be haled into court there.
5. Asahi Metal Industry v. Superior Court (SCOTUS 1986)
Gary Zurcher was injured when his motorcycle tire failed. He sued the Taiwanese manufacturer of the tire tube, which cross-complained against Asahi, the Japanese manufacturer of the tire tube's valve. The court in this case further refined the limits of corporate personal jurisdiction. It held that awareness that a product would enter the forum state in the stream of commerce wasn't enough to confer jurisdiction; the defendant had to purposefully direct its product to the forum state. Because Asahi made little metal valves that ultimately ended up all over the place, it didn't specifically direct its conduct at California.
Pennoyer v. Neff 一 Proceedings to determine the personal rights and obligations of parties over whom the court has no jurisdiction do not constitute due process. The Bremen v. Zapata Off-Shore Co. 一 A forum selection clause that was a vital part of a towing contract is binding unless the party challenging its enforcement can meet the heavy burden of showing that its enforcement would be unreasonable, unfair, or unjust. Carnival Cruise Lines, Inc. v. Shute 一 A non-negotiated forum clause in a passage contract may be enforceable even though it is not the subject of bargaining, although it is subject to judicial scrutiny for fundamental fairness. International Shoe Co. v. Washington 一 To subject a defendant to personal jurisdiction when they are not present in the territory of the forum, the defendant must have certain minimum contacts with the forum such that the maintenance of the lawsuit does not offend traditional notions of fair play and substantial justice. Burnham v. Superior Court 一 Service of process confers state court jurisdiction over a physically present non-resident, regardless of whether they were only briefly in the state or whether the cause of action is related to their activities there. Tickle v. Barton 一 Personal service of process is void when it was obtained by inveigling or enticing the person to be served into the territorial jurisdiction of the court by fraud or deceit. Shaffer v. Heitner 一 When the property serving as the basis for state court jurisdiction is completely unrelated to the plaintiff’s cause of action, the presence of the property alone does not support jurisdiction without other ties among the defendant, the state, and the litigation. Hess v. Pawloski 一 Due process does not prevent a state from declaring that the use of its highways by a non-resident motorist shall be deemed equivalent to an appointment by the motorist of the registrar as their attorney, upon whom process may be served in any action arising out of an accident in which the non-resident was involved. Gray v. American Radiator & Standard Sanitary Corp. 一 Personal jurisdiction is satisfied either if the act or transaction from which the case arose occurred in the state, or if the defendant engaged in a sufficiently substantial course of activity in the state. World-Wide Volkswagen Corp. v. Woodson 一 The foreseeability that is critical to due process analysis is that the defendant’s conduct and connection with the forum are such that they should reasonably anticipate being brought into court there. Burger King Corp. v. Rudzewicz 一 A contract with an out-of-state party does not alone automatically establish sufficient minimum contacts in the other party’s home forum. Instead, the court must evaluate the prior negotiations, the contemplated future consequences, the terms of the contract, and the parties’ actual course of dealing to determine whether a defendant purposefully established minimum contacts within the forum.
Asahi Metal Industry Co. v. Superior Court 一 The substantial connection between a defendant and the forum state necessary for a finding of minimum contacts must derive from an action purposely directed toward the forum state. The mere placement of a product into the stream of commerce is not such an act, even if done with an awareness that the stream will sweep the product into the forum state, without additional conduct indicating an intent to serve the forum state market. J. McIntyre Machinery, Ltd. v. Nicastro 一 Generally, the exercise of judicial power is not lawful unless the defendant purposefully avails itself of the privilege of conducting activities within the forum state, thus invoking the benefits and protections of its laws. A foreign manufacturer was not subject to jurisdiction when it did not target the state in any relevant sense. Goodyear Dunlop Tires Operations, S.A. v. Brown 一 Ties serving to bolster the exercise of specific jurisdiction do not warrant a determination that, based on those ties, the forum has general jurisdiction over a defendant. BNSF Railroad Co. v. Tyrrell 一 A court may assert general jurisdiction over out-of-state corporations to hear any and all claims against them when their affiliations with the state are so continuous and systematic as to render them essentially at home in the forum state. Bristol-Myers Squibb Co. v. Superior Court of California 一 When there is no connection between the forum and the underlying controversy, specific jurisdiction is lacking regardless of the extent of a defendant’s unconnected activities in the state. Ford Motor Co. v. Montana Eighth Judicial District Court 一 When a company serves a market for a product in a state, and that product causes an injury in the state to one of its residents, the state’s courts may entertain the resulting lawsuit. Zippo Manufacturing Co. v. Zippo Dot Com, Inc. 一 Personal jurisdiction is proper when a defendant clearly does business over the internet, while a passive website that does little more than make information available is not grounds for personal jurisdiction. For interactive websites where a user can exchange information with the host computer, the exercise of jurisdiction is determined by examining the level of interactivity and commercial nature of the exchange of information on the website. Insurance Corp. of Ireland v. Compagnie des Bauxites 一 Since the requirement that a court have personal jurisdiction protects an individual interest, it may be intentionally waived, or a defendant may be estopped from raising the issue for various reasons. Subject Matter Jurisdiction Subject matter jurisdiction means that the court has the authority to review the type of case at issue. A federal court generally holds diversity jurisdiction if no plaintiff is a citizen of the same state as any defendant in the case, and the amount in controversy is over $75,000. Meanwhile, federal question jurisdiction exists if a case arises under federal law.
Aldinger v. Howard 一 A non-federal claim should not be the basis for joining a party over whom no independent federal jurisdiction exists, simply because that claim derives from the common nucleus of operative fact giving rise to the dispute between the parties to the federal claim. Owen Equipment and Erection Co. v. Kroger 一 A finding that federal and non-federal claims arise from a common nucleus of operative fact does not suffice to establish that a federal court has the power to hear non-federal as well as federal claims. Although the constitutional power to adjudicate the non-federal claim may exist, it does not necessarily follow that statutory authorization has been granted. The context in which a non-federal claim is asserted is crucial. Finley v. U.S. 一 A grant of jurisdiction over claims involving particular parties does not confer jurisdiction over additional claims by or against different parties. Exxon Mobil Corp. v. Allapattah Services, Inc. 一 A court with original jurisdiction over a single claim in the complaint has original jurisdiction over a civil action under Section 1367(a), even if that action comprises fewer claims than were included in the complaint. Venue and Choice of Law Rules regarding venue protect defendants from being forced to defend a case in an extremely inconvenient or arbitrary location. Sometimes a defendant will bring a forum non conveniens motion, which alleges that the case could have been brought in a more appropriate venue. Courts also may face complex questions regarding which jurisdiction’s law should apply. Bates v. C&S Adjusters, Inc. 一 Receipt of a collection notice is a substantial part of the events giving rise to a claim under the Fair Debt Collection Practices Act. More generally, the statutory standard for venue focuses not on whether a defendant has made a deliberate contact but on the location where events occurred. Hoffman v. Blaski 一 A federal district court in which a civil action has been properly brought is not empowered to transfer the action on the motion of the defendant to a district in which the plaintiff did not have a right to bring it. Erie Railroad Co. v. Tompkins 一 A federal court exercising diversity jurisdiction must apply the state law as declared by the highest state court. There is no federal general common law. Klaxon Co. v. Stentor Electric Manufacturing Co., Inc. 一 Federal courts deciding questions of conflict of laws in diversity of citizenship cases must follow the rules prevailing in the states in which they sit. Allstate Insurance Co. v. Hague 一 A state court could apply the law of its state when the state had a significant aggregation of contacts with the parties and the occurrence, creating state interests, such that the application of its law was neither arbitrary nor fundamentally unfair.
Van Dusen v. Barrack 一 When actions were properly brought in the transferor district court, and the defendants seek transfer under Section 1404(a), the change of venue should not be accompanied by a change in the governing state laws. Gulf Oil Corp. v. Gilbert 一 Important considerations in the application of the forum non conveniens doctrine from the standpoint of litigants are relative ease of access to sources of proof, availability of compulsory process for attendance of unwilling witnesses, cost of obtaining attendance of willing witnesses, the possibility of viewing the premises if appropriate, and other practical problems that make trial of a case easy, expeditious, and inexpensive. Considerations of public interest include the undesirability of piling up litigation in congested centers, the burden of jury duty on people of a community with no relation to the litigation, the local interest in having localized controversies decided at home, and the unnecessary injection of problems in conflict of laws. Piper Aircraft Co. v. Reyno 一 Plaintiffs may not defeat a motion to dismiss on the ground of forum non conveniens merely by showing that the substantive law that would be applied in the alternative forum is less favorable to them than the law of the chosen forum. Atlantic Marine Construction Co. v. U.S. District Court for Western District of Texas 一 A forum selection clause may be enforced by a motion to transfer under Section 1404(a). When a defendant files such a motion, a district court should transfer the case unless extraordinary circumstances unrelated to the convenience of the parties clearly disfavor a transfer. Complaints and Claims A complaint is the document that a plaintiff files to start a lawsuit. A defendant then may file an answer to the complaint, which may include a counterclaim by the defendant against the plaintiff. Sometimes a defendant tries to get a complaint dismissed for failing to state a claim. Dioguardi v. Durning 一 There is no pleading requirement of stating facts sufficient to constitute a cause of action, but only that there be a short and plain statement of the claim showing that the pleader is entitled to relief. Conley v. Gibson 一 A complaint should not be dismissed for failure to state a claim unless it appears beyond doubt that the plaintiff can prove no set of facts in support of their claim that would entitle them to relief. Bell Atlantic Corp. v. Twombly 一 A plaintiff must plead enough facts to state a claim to relief that is plausible on its face. Ashcroft v. Iqbal 一 The tenet that a court must accept as true all of the allegations contained in a complaint is inapplicable to legal conclusions. Swierkiewicz v. Sorema N.A. 一 An employment discrimination complaint need not contain specific facts establishing a prima facie case but instead must contain only a short and plain statement of the claim showing that the pleader is entitled to relief.
Hansberry v. Lee 一 A judgment rendered in a class suit may be res judicata as to members of the class who are not formal parties to the suit. There is a failure of due process only in cases in which it cannot be said that the procedure adopted fairly ensures the protection of the interests of absent parties who are to be bound by it. Discovery If an action survives any early motions to dismiss, the parties will proceed through the process of discovery. This involves exchanging information about documents and witness testimony that will be presented at trial. Upjohn Co. v. U.S. 一 The attorney-client privilege exists to protect not only the giving of professional advice to those who can act on it, but also the giving of information to the lawyer to enable them to give sound and informed advice. However, the privilege only protects disclosure of communications, rather than disclosure of the underlying facts. Hickman v. Taylor 一 Memoranda, statements, and mental impressions prepared or obtained from interviews with witnesses by counsel in preparing for litigation after a claim has arisen are not within the attorney-client privilege. However, a party who would invade the privacy of an attorney’s course of preparation must establish adequate reasons to justify production through a subpoena or court order. Summary Judgment Summary judgment can end a case before it proceeds to a full trial before a jury. A judge in a federal court may grant summary judgment if there is no genuine dispute about any material fact in the case, and the moving party is entitled to judgment as a matter of law. Adickes v. S.H. Kress & Co. 一 A party moving for summary judgment has the burden of showing the absence of a genuine issue as to any material fact. For these purposes, the material submitted by the moving party must be viewed in the light most favorable to the opposing party. Celotex Corp. v. Catrett 一 Rule 56(c) mandates the entry of summary judgment, after adequate time for discovery and upon motion, against a party who fails to make a showing sufficient to establish the existence of an element essential to that party’s case, and on which that party will bear the burden of proof at trial. Scott v. Harris 一 When opposing parties tell two different stories, one of which is blatantly contradicted by the record so that no reasonable jury could believe it, a court should not adopt that version of the facts for the purposes of ruling on a motion for summary judgment. Anderson v. Liberty Lobby, Inc. 一 The inquiry involved in a ruling on a motion for summary judgment or for a directed verdict necessarily implicates the substantive evidentiary standard of proof that would apply at the trial on the merits.
Matsushita Electrical Industrial Co., Ltd. v. Zenith Radio Corp. 一 The absence of any plausible motive to engage in the conduct charged is highly relevant to whether a genuine issue for trial exists within the meaning of Rule 56(e). Lack of motive bears on the range of permissible conclusions that might be drawn from ambiguous evidence. Lundeen v. Cordner 一 A party opposed to a summary judgment based on affidavits must assume some initiative in showing that a factual issue actually exists. Cross v. U.S. (^) 一 Summary judgment is particularly inappropriate when the inferences that the parties seek to have drawn deal with questions of motive, intent, and subjective feelings and reactions. Valley National Bank of Arizona v. J.C. Penney Ins. Co. 一 Even if there is no factual dispute, when possible inferences to be drawn from the circumstances are conflicting, a summary disposition is unwarranted. Houchens v. American Home Assurance Co. 一 Piling inferences on inferences is not a proper way to avoid summary judgment. Trials and Appeals If a case reaches a trial, judges and counsel have some discretion over who may sit on a jury, but their discretion is subject to certain constitutional limits. In most cases, a trial court order must be “final” to be subject to appellate review. Appellate courts give deference to trial court decisions regarding facts but not to decisions regarding the law. Chauffeurs Local 391 v. Terry 一 To determine whether a particular action will resolve legal (as opposed to equitable) rights, such that the plaintiff is entitled to a jury trial, courts must examine both the nature of the issues involved and, more importantly, the remedy sought. Beacon Theatres, Inc. v. Westover 一 Only under the most imperative circumstances can the right to a jury trial of legal issues be lost through prior determination of equitable claims. Flowers v. Flowers 一 Juror disqualification for bias or prejudice extends not only to the parties personally but also to the subject matter of the litigation. Edmonson v. Leesville Concrete Co., Inc. 一 A private litigant in a civil case may not use peremptory challenges to exclude jurors on account of race. J.E.B. v. Alabama ex rel. T.B. 一 The Equal Protection Clause prohibits discrimination in jury selection on the basis of gender, or on the assumption that an individual will be biased in a particular case solely because that person happens to be a woman or a man. Lavender v. Kurn 一 When there is an evidentiary basis for the jury’s verdict, the jury is free to discard or disbelieve whatever facts are inconsistent with its conclusion. The appellate court’s
to relitigate through a proxy; and when a special statutory scheme consistent with due process expressly forecloses successive litigation by non-litigants. Lucky Brand Dungarees, Inc. v. Marcel Fashions Group, Inc. 一 Any preclusion of defenses must, at a minimum, satisfy the strictures of issue preclusion or claim preclusion. This outline has been compiled by the Justia team for solely educational purposes and should not be treated as an independent source of legal authority or a summary of the current state of the law. Students should use this outline as a supplement rather than a substitute for course- specific outlines.
