PJ SMJ Rule

Introduction PJ

Personal jurisdiction is the court’s power over a defendant or the defendant’s property. It must first be authorized by the forum state’s long-arm statute and then satisfy due process under the Fourteenth Amendment. Exercising jurisdiction must not offend traditional notions of fair play and substantial justice. Under Pennoyer v. Neff, jurisdiction may be based on traditional grounds such as domicile, in-forum service, consent, waiver, tag jurisdiction, or attached property. If no traditional basis applies, the court uses International Shoe v. Washington, which requires the defendant to have minimum contacts with the forum and that exercising jurisdiction be fair and reasonable.

Long-Arm Statute

A court must first determine whether the forum state’s long-arm statute authorizes jurisdiction over the defendant. The court must then determine whether exercising jurisdiction satisfies constitutional due process. In federal court, Rule 4(k)(1)(A) generally provides that the court uses the jurisdictional reach of the state in which it sits.

General Jurisdiction

General jurisdiction allows a court to hear any claim against a defendant whose forum contacts are so continuous and systematic as to render them essentially at home there, without requiring the claim to arise from those contacts (Daimler; Goodyear); for individuals this is generally based on domicile (physical presence plus intent to remain indefinitely), while for corporations it generally exists in the state of incorporation and principal place of business—defined as its "nerve center" where high-level officers direct, control, and coordinate activities (Hertz)—though an exceptional case may establish a defendant is at home beyond these usual locations (Perkins), provided that extensive business activity alone remains insufficient.

Specific Jurisdiction

Specific jurisdiction requires the defendant to purposefully establish contacts with the forum—shown via deliberate conduct and purposeful availment rather than unilateral plaintiff action (Hanson), mere foreseeability (World-Wide Volkswagen), or stream-of-commerce placement alone without additional targeting like forum-specific advertising, product design, or distribution (World-Wide Volkswagen; Asahi; J. McIntyre), though deliberate and continuing contractual relationships (Burger King; McGee), intentional acts expressly aimed at the forum under the Calder effects test where the brunt of harm is felt, or active internet business under the Zippo sliding scale framework can suffice—while requiring the claim to arise out of or relate to those contacts and the exercise of jurisdiction to be fair and reasonable.

Relatedness

The plaintiff’s claim must arise out of or relate to the defendant’s contacts with the forum. Strict but-for causation is not always required. (Ford Motor Co. v. Montana Eighth Judicial District Court). Each plaintiff must establish a connection between their claim and the defendant’s forum contacts. (Bristol-Myers Squibb Co. v. Superior Court).

Fairness and Reasonableness

Even when minimum contacts exist, exercising jurisdiction must be fair and reasonable. Courts consider five factors: the burden on the defendant, the forum state’s interest in adjudicating the dispute, the plaintiff’s interest in obtaining convenient and effective relief, the interstate judicial system’s interest in efficient resolution, and the shared interests of the states in furthering fundamental substantive social policies. (Asahi Metal Industry Co. v. Superior Court).

Waiver of Personal Jurisdiction

A defendant may waive an objection to personal jurisdiction by failing to raise it in the first Rule 12 motion or responsive pleading as required by Rules 12(g) and 12(h)(1).

General Rule smj

Federal courts are courts of limited jurisdiction. A federal district court may hear a case only when the Constitution permits federal jurisdiction and Congress has authorized jurisdiction by statute. Subject matter jurisdiction cannot be waived or created by consent, stipulation, or delay. Any party or the court may raise the issue. Under Rule 12(h)(3), if the court determines at any time that subject matter jurisdiction is lacking, it must dismiss the action.

Federal Question Jurisdiction

Federal question jurisdiction under 28 U.S.C. Section 1331 exists over civil actions arising under federal law, which is generally determined by the Holmes creation test or when a state-law claim necessarily raises an actually disputed, substantial federal issue resolvable without disrupting the federal-state balance (Grable; Gunn), though a state-law malpractice claim does not automatically qualify (Hays), and under the well-pleaded complaint rule—where the plaintiff is master of the complaint and anticipated defenses or responses do not suffice (Mottley)—a qualifying federal issue must appear on the face of a properly pleaded complaint or justify recharacterization via the artful pleading doctrine or narrow complete preemption.

Diversity Jurisdiction

Diversity jurisdiction requires complete diversity—meaning no plaintiff shares state citizenship with any defendant (Strawbridge v. Curtiss) measured at filing—and an amount in controversy exceeding $75,000, exclusive of interest and costs, where the plaintiff's good-faith allegation controls unless legally certain to be less. Individual citizenship is determined by domicile (physical presence plus intent to remain indefinitely), corporations are citizens of their place of incorporation and principal place of business ("nerve center" under Hertz Corp. v. Friend), LLCs and partnerships take the citizenship of every member or partner, and representatives of estates, minors, or incompetents assume the represented person's citizenship, while CAFA provides alternative minimal-diversity rules for qualifying class actions. Regarding the amount in controversy, a single plaintiff may aggregate claims against one defendant, whereas separate plaintiffs generally cannot aggregate distinct claims unless sharing a common, undivided interest.

Supplemental Jurisdiction

Under 28 U.S.C. Section 1367(a), supplemental jurisdiction allows a court with original jurisdiction over at least one claim to hear related claims sharing a common nucleus of operative fact (United Mine Workers v. Gibbs), provided a valid anchor claim exists.

Under Section 1367(b), diversity-only cases bar supplemental jurisdiction over certain plaintiff claims against joined parties (Rules 14, 19, 20, 24) that would destroy complete diversity.

Under Section 1367(c), courts may decline supplemental jurisdiction for novel or complex state law issues, substantial state law predominance, dismissal of all original jurisdiction claims, or exceptional circumstances.

Under Section 1367(d), the limitations period for qualifying state-law claims is tolled for at least 30 days after dismissal to allow time for refiling in state court.