⚡ 10-Second Rule
A state's court can only order you around if you live there, agree, get caught there, or built real connections there.
🧒 ELI-10 Scene
Priya plays soccer in the Maplewood kids' league. She practices there every week. Maplewood refs can call her out for anything she does, anytime. That league is her home base. One Saturday she plays a single away game in Oakdale. Oakdale refs can penalize her — but only for things she did in that game. Her brother Dev has never set foot in Oakdale. Oakdale refs cannot touch Dev at all. He never chose to play on their field. Courts work the same way. Your home court can hear anything. A visited court hears only what you did there. A stranger's court hears nothing.
⚖️ Actual Rule
Under International Shoe Co. v. Washington, 326 U.S. 310 (1945), due process permits a court to bind an absent defendant only if the defendant has "certain minimum contacts with it such that the maintenance of the suit does not offend 'traditional notions of fair play and substantial justice.'" Contacts count only if the defendant "purposefully avails itself of the privilege of conducting activities within the forum State, thus invoking the benefits and protections of its laws." Hanson v. Denckla, 357 U.S. 235 (1958). General jurisdiction — power over any claim — exists only where the defendant is "at home": for individuals, domicile; for corporations, essentially the state of incorporation and the principal place of business. Daimler AG v. Bauman, 571 U.S. 117 (2014). Specific jurisdiction requires that the claim arise out of or relate to the defendant's forum contacts. Ford Motor Co. v. Montana Eighth Judicial District Court, 592 U.S. 351 (2021). Traditional bases remain valid: in-state personal service (Burnham v. Superior Court, 495 U.S. 604 (1990)), domicile, and consent. Statutory step: a state long-arm statute must authorize jurisdiction, and federal courts generally borrow the forum state's reach under Federal Rule of Civil Procedure 4(k)(1)(A). [NJ-VARIANT: flagged for future Eli Explains NJ Law module]
ELI-10 translation: the court needs a state law that says "we can grab you," plus fair, chosen connections to the state.
🔍 Ask These Questions
- Does a traditional basis apply — served in the state, domiciled there, or consented? (Was the defendant tagged there, does she live there, or did she say yes?)
- Does the state's long-arm statute authorize jurisdiction over this defendant? (Does the state's own rulebook even try to grab this person?)
- Did the defendant purposefully avail itself of the forum — its own deliberate contacts, not someone else's? (Did the defendant choose to reach into the state on purpose?)
- Is the defendant at home in the forum — domicile, incorporation, or principal place of business? (Is this the defendant's home base, where any claim can be heard?)
- If not at home, does the claim arise out of or relate to the forum contacts? (Is the lawsuit about what the defendant actually did in this state?)
- Would jurisdiction satisfy fair play and substantial justice — burden, forum interest, plaintiff's interest? (Even with contacts, would making the defendant come here be truly unfair?)
⚠️ Bar Trap
Exam language: Examiners describe a corporation with "continuous and substantial" sales in the forum and bait you into finding general jurisdiction over an unrelated claim. After Daimler, doing lots of business in a state does not make a corporation "at home" there; general jurisdiction essentially requires the state of incorporation or the principal place of business. The mirror trap: unilateral acts of the plaintiff or a third party — like driving the defendant's product into the forum — are not the defendant's contacts.
ELI-10: Big sales in a state do not make it the company's home base. And someone else carrying your stuff into a state is not you choosing that state.
🧪 Question
Sky Loft Drones, Inc. is incorporated in Nevada with its principal place of business in Nevada. It sells drones through independent retailers in all fifty states, and Colorado accounts for fifteen percent of its annual revenue. A Utah hiker purchased a Sky Loft drone at a Utah retailer; the drone malfunctioned and injured him while he was hiking in Utah. The hiker sued Sky Loft in a Colorado court, and Sky Loft moved to dismiss for lack of personal jurisdiction. Colorado's long-arm statute extends to the limits of due process.
Should the court grant the motion?
(A) No, because Sky Loft's continuous and substantial sales in Colorado subject it to general jurisdiction there. (B) No, because Sky Loft purposefully availed itself of the Colorado market by selling through Colorado retailers. (C) Yes, because Sky Loft is not at home in Colorado and the claim neither arises out of nor relates to its Colorado contacts. (D) Yes, because a corporation may be sued only in its state of incorporation.
Answer: (C). Sky Loft is at home only in Nevada, so Colorado lacks general jurisdiction despite substantial sales. Specific jurisdiction fails because the purchase, malfunction, and injury all occurred in Utah, unconnected to Sky Loft's Colorado contacts.
💡 Why the Wrong Answers Are Wrong
- (A) applies the pre-Daimler myth that heavy in-forum sales create general jurisdiction; "at home" essentially means incorporation or principal place of business.
- (B) finds real purposeful availment but ignores the second requirement of specific jurisdiction: the claim must arise out of or relate to those forum contacts.
- (D) overcorrects; a corporation is also at home at its principal place of business, and specific jurisdiction can reach it in many other states.
- ELI-10: The misconception is mixing up the two doors. The "home" door opens for any claim; the "visitor" door opens only for claims about what happened there.
