A plaintiff files a lawsuit in State A against a defendant who resides in State B. The defendant owns no property in State A, has no permanent presence there, and has not personally visited. However, the defendant operates an e-commerce website accessible to residents of State A, and 5% of the website's annual sales are to customers in State A. The defendant moves to dismiss for lack of personal jurisdiction. How should the court rule?
The court should grant the motion because mere accessibility of a website in State A is not enough to establish personal jurisdiction.
The court should deny the motion if the website shows that the defendant purposefully directed activities toward State A residents and the lawsuit arises because of those activities.
The court should deny the motion if the defendant's connections with State A are sufficient to establish general jurisdiction.
The court should grant the motion because the defendant has no physical presence in State A and does not own property there.
The correct answer is that the court should deny the motion if the defendant has purposefully directed activities toward residents of State A through their e-commerce website and if the cause of action arises from those activities. This aligns with the 'minimum contacts' test established by the Supreme Court in International Shoe Co. v. Washington, which requires that a defendant have certain minimum contacts with the forum state such that maintaining the lawsuit does not offend 'traditional notions of fair play and substantial justice.' The percentage of sales to State A helps establish purposeful availment.
The incorrect answers rely on misapplications of personal jurisdiction principles. For example, merely making the website accessible in the forum state is insufficient without targeting residents there, and physical presence is not required to establish jurisdiction under modern case law. Similarly, general jurisdiction is not established if the connections with State A are not so systematic and continuous as to render the defendant essentially at home there.
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