Personal Jurisdiction Over an Out-of-State Online Seller
A buyer in State A orders a $600 custom bicycle frame from a two-person shop in State B. The shop's website accepts orders nationwide, but 90% of sales are within 200 miles of its storefront, it has no employees or property in State A, and it has shipped only four orders to State A in three years. The frame arrives cracked, and the buyer sues in State A court for breach of warranty and negligence. The shop moves to dismiss for lack of personal jurisdiction, submitting an affidavit with the sales figures. The buyer argues the shop 'purposefully availed itself of the national market' by having a website. The state's long-arm statute reaches the constitutional limit.
1. Apply the purposeful-availment and relatedness prongs to these facts.
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Because the long-arm statute reaches the constitutional limit, the only question is due process: minimum contacts, purposeful availment, relatedness, and fair play.
Purposeful availment: merely operating a website that can be accessed nationwide is not enough. Courts look for conduct targeting the forum-shipping into it, advertising there, or a course of dealing. Four shipments in three years, with 90% of business local, is not a purposeful targeting of State A. It resembles isolated or sporadic contact rather than deliberate exploitation of the forum market.
Relatedness: the claim (cracked frame) does arise from the one shipment into State A, which helps the buyer on relatedness. But relatedness cannot rescue a case with no purposeful contact.
Conclusion: no purposeful availment, so no specific jurisdiction.
2. Could general jurisdiction or fair play change the outcome?
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General jurisdiction requires the defendant to be 'at home' in the forum-typically its place of incorporation or principal place of business. A two-person shop in State B is at home in State B, not State A. No general jurisdiction.
Fair play (reasonableness) factors-burden on the defendant, forum state's interest, plaintiff's interest, efficiency, and shared substantive interests-are considered only after minimum contacts are found. Here they are not reached, though the burden on a two-person out-of-state shop would weigh heavily against jurisdiction anyway.
Ruling: grant the motion to dismiss for lack of personal jurisdiction. The buyer may sue in State B, where the shop is at home, or pursue a small-claims action there.