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Greiner Civil Procedure Version 02

Griffis v. Luban

The type of personal jurisdiction at issue in the next case is specific personal jurisdiction – jurisdiction over a claim that allegedly arose out of the defendant's contacts with the forum. The plaintiff contended that the defendant had sufficient contacts with Alabama to support the Alabama court's exercise of personal jurisdiction. In prior personal jurisdiction cases, the location of the defendant’s conduct was important.  Where did the defendant’s conduct take place in the following case?  Similarly, sometimes the place of the injury matters (although from J. McIntyre, we know that it is not enough for personal jurisdiction).  Where did the injury occur here?

This case summarizes, but does not follow faithfully, a 9-0 SCOTUS opinion called Calder v. Jones.  As it turns out, the Supreme Court subsequently adopted law much like what the Minnesota Supreme Court articulates in this case, likely overruling Calder.