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Personal Jurisdiction Explained: You Cannot Be Sued Just Anywhere

Posted by Bradley V. Sneed | Jul 22, 2019

Subject Matter Jurisdiction vs. Personal Jurisdiction 

Generally speaking, there are two "jurisdictional" hurdles that must be satisfied in every lawsuit.  First, does the court have subject matter jurisdiction to hear the case?  Second, does the court have personal jurisdiction over the parties to make a ruling affecting their rights?

Subject matter jurisdiction is focused on whether the court has been given the authority to hear the type of case that was filed.  Many state court systems are divided into different divisions, so there are specific courts to hear specific kinds of cases, i.e., criminal, civil, family, probate, etc. So in those states, a court given jurisdiction to hear criminal matters, would lack subject matter jurisdiction to hear a probate case.  In Idaho, the court system is not divided into specific divisions like these, but rather is divided based on the amount of damages in dispute and/or the level of the crime being charged (felony vs. misdemeanor) Idaho's district courts have subject matter jurisdiction over civil and criminal cases, including personal injury cases, contract disputes, propertry disputes, and felony criminal cases, while the magistrate courts have subject matter jurisdiction over civil actions involving $10,000 or less in claimed damages (like personal injury, property disputes, contracts, etc.), small claims ($5,000 or less in dispute), traffic infractions, probate matters, juvenile corrections, misdemeanor crimes, and family/divorce cases.  Typically in Idaho, subject matter jurisdiction is easy to demonstrate and it is rarely a contested issue/     

On the other hand, challenges to personal jurisdiction are much more frequent.  Personal jurisdiction is focused on the following question: "the foreseeability that the defendant's conduct and connection with the forum State are such that the defendant should reasonably anticipate being haled into court there."  Can you be sued by someone in Idaho, if you've never even been to Idaho and have no connections to Idaho? 

The Idaho Supreme Court has made it clear that "the proper exercise of personal jurisdiction over non-resident defendants by an Idaho court involves satisfying two criteria.  First, the court must determine that the non-resident defendant's actions fall within the scope of Idaho's long-arm statute (discussed below). Second, the court must determine that exercising jurisdiction over the non-resident defendant comports with the constitutional standards of the Due Process Clause of the U.S. Constitution. 

Idaho's Long-Arm Statute

Idaho's long-arm statute (Idaho Code § 5-514) sets forth the acts which will subject a company to the jurisdiction of the courts of the State of Idaho.  An Idaho court will have personal jurisdiction over a defendant only if the defendant (a) transacted business within Idaho; (b) committed a tortious act within Idaho, like a car wreck for example; (c) owns, uses, or possesses any real property within Idaho; (d) contracted to insure any person, property, or risk within Idaho; (e) maintained a matrimonial domicile within Idaho at the time of any act giving rise to a cause of action for divorce; or (f) engaged in an act of sexual intercourse within Idaho giving rise to a cause of action for paternity.       

Idaho Code § 5-514 defines “transaction of business” as “doing any act for the purpose of realizing pecuniary benefit or accomplishing or attempting to accomplish, transact or enhance the business purpose or objective or any part thereof of such company.”  So if a company did not transact any business within Idaho, did not commit any tortious act within Idaho, and does not own, use, or possess any real property in Idaho, then that company will not have the “minimum contacts” with Idaho for the court to exercise personal jurisdiction.  But even in those cases where an Idaho determines the long-arm statute applies to a defendant's actions affecting Idaho or committed within Idaho, such a court would then have to determine if the lawsuit nonetheless would violate the applicable due process considerations.     

Due Process Analysis

The Fourteenth Amendment to the U.S. Constitution permits a state to exercise personal jurisdiction over a non-resident defendant when that defendant has certain minimum contacts with the state such that the maintenance of the suit does not offend ‘traditional notions of fair play and substantial justice.  “In determining the existence of minimum contacts, a court must focus on the relationship among the defendant, the forum, and the litigation.”  “Once a court finds the requisite minimum contacts, it must then proceed to determine whether its assertion of personal jurisdiction comports with traditional notions of fair play and substantial justice.”

This due process analysis permits the court to consider: (a) “the burden on the defendant”; (b) “the forum State's interest in adjudicating the dispute”; (c) “the plaintiff's interest in obtaining convenient and effective relief”; (d) “the interstate judicial system's interest in obtaining the most efficient resolution of controversies”; and (e) the “shared interest of the several States in furthering fundamental substantive social policies.” 

These considerations sometimes serve to establish the reasonableness of jurisdiction upon a lesser showing of minimum contacts than would otherwise be required. On the other hand, where a defendant who purposefully has directed his activities at Idaho residents seeks to defeat jurisdiction, he must present a compelling case that the presence of some other considerations would render jurisdiction unreasonable under the circumstances.

Generally, the Due Process Clause requires that a non-resident of Idaho have “fair warning that a particular activity may subject [them] to the jurisdiction of a foreign sovereign,” and “gives a degree of predictability to the legal system that allows potential defendants to structure their primary conduct with some minimum assurance as to where that conduct will and will not render them liable to suit.”  In defining when it is that a potential defendant should “reasonably anticipate” out-of-state litigation, the U.S. Supreme Court frequently has relied upon the following test: "it is essential in each case that there be some act by which the defendant purposefully avails itself of the privilege of conducting activities within the forum State, thus invoking the benefits and protections of its laws.”

In summary, the question of whether a court has personal jurisdiction in a case can be complicated and can require a complex factual analysis to detemine if a party has necessary minimum contacts with Idaho and whether the party should have reasonably anticipated being sued in Idaho, based on his/her actions related to Idaho.  Obviously, these type of personal jurisdiction inquires will rely heavily on the facts of each specific case.

About the Author

Bradley V. Sneed

Brad represents clients in family law (divorce, child custody/support modifications, guardianships), employment disputes (employers and employees), construction disputes, and insurance coverage dispute litigation.  If you find yourself faced with the need for legal guidance in any of these fields, contact Brad so he can take all steps necessary to protect you.

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