Sherwin Brook v. J. McCormley, 873 F.3d 549 (7th Cir. 2017). · Go Syfert
Sherwin Brook v. J. McCormley, 873 F.3d 549 (7th Cir. 2017). Cases Citing This Book View Copy Cite
251 citation events (251 in the last 25 years) across 14 distinct courts.
Strongest positive: Smith v. SMS Group Inc. (ilsd, 2023-06-02)
Treatment trajectory · 2017 → 2026 · click a year to view as-of
2017 2021 2026
Top citers, strongest first. 50 distinct citers. How cited ↗
examined Cited as authority (verbatim quote) Smith v. SMS Group Inc. (3×) also: Cited as authority (rule)
S.D. Ill. · 2023 · quote attribution · 1 verbatim quote · confidence high
specific jurisdiction requires a defendant's contacts with the forum state to be directly related to the conduct pertaining to the claims asserted.
discussed Cited as authority (verbatim quote) Clark v. McDonald's Corporation (2×) also: Cited as authority (rule)
S.D. Ill. · 2023 · quote attribution · 1 verbatim quote · confidence high
specific jurisdiction requires a defendant's contacts with the forum state to be directly related to the conduct pertaining to the claims asserted.
discussed Cited as authority (verbatim quote) Golbert v. Aurora Chicago Lakeshore Hospital LLC
N.D. Ill. · 2022 · signal: see · quote attribution · 1 verbatim quote · confidence high
specific jurisdiction requires a defendant's contacts with the forum state to be directly related to the conduct pertaining to the claims asserted.
discussed Cited as authority (verbatim quote) McGoveran v. Amazon Web Services, Inc. (2×) also: Cited as authority (rule)
S.D. Ill. · 2020 · quote attribution · 1 verbatim quote · confidence high
specific jurisdiction requires a defendant's contacts with the forum state to be directly related to the conduct pertaining to the claims asserted.
examined Cited as authority (verbatim quote) Monco v. Zoltek Corporation (4×) also: Cited as authority (rule), Cited "see"
N.D. Ill. · 2019 · signal: see · quote attribution · 1 verbatim quote · confidence high
the mere fact that a defendant's conduct affects a plaintiff with connections to the forum state is not sufficient to establish jurisdiction
discussed Cited as authority (verbatim quote) Mission Measurement Corp. v. Blackbaud, Inc. (2×) also: Cited as authority (rule)
E.D. Ill. · 2017 · signal: see · quote attribution · 1 verbatim quote · confidence high
the relationship must arise out of contacts that the defendant himself creates with the forum state," and "the defendant's contacts with the forum state itself.
discussed Cited as authority (quoted) Philips Medical Systems (Cleveland), Inc. v. Buan (2×) also: Cited "see"
N.D. Ill. · 2025 · signal: see also · quote attribution · 1 verbatim quote · confidence low
in order for a district court to bind an individual, the court must have personal jurisdiction over the individual
discussed Cited as authority (rule) Aquatech Corporation v. Dutch Barn, LLC, et al.
N.D. Ill. · 2026 · confidence medium
“The Illinois long- arm statute permits the court to exercise jurisdiction to the full extent permitted by the Due Process Clause of the Fourteenth Amendment.” Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017) (citing 735 ILCS 5/2-209(c)).
discussed Cited as authority (rule) United States Gypsum Company v. Dependable LLC
N.D. Ill. · 2025 · confidence medium
Illinois employs a long-arm statute which applies the same standard as federal due process: a defendant must have sufficient contacts with the forum state “such that the maintenance of the suit does not offend traditional notions of fair play and substantial justice.” Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017), quoting Int’l Shoe Co. v. Washington, 326 U.S. 310, 316 (1945).
discussed Cited as authority (rule) Suncast Corporation v. Thurman
N.D. Ill. · 2025 · confidence medium
Illinois employs a long-arm statute which applies the same standard as federal due process: a defendant must have sufficient contacts with the forum state “such that the maintenance of the suit does not offend traditional notions of fair play and substantial justice.” Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017), quoting Int’l Shoe Co. v. Washington, 326 U.S. 310, 316 (1945).
discussed Cited as authority (rule) Weinstock v. Islamic Republic of Iran
N.D. Ill. · 2025 · confidence medium
"The Illinois long-arm statute permits the court to exercise jurisdiction to the full extent permitted by the Due Process Clause of the Fourteenth Amendment." Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017) (citing 735 ILCS 5/2-209(c)).
discussed Cited as authority (rule) Meihua v. Individuals, Partnerships identified in Schedule A
N.D. Ill. · 2025 · confidence medium
Minimum contacts exist where “the defendant’s conduct and connection with the forum State are such that he should reasonably anticipate being haled into court there.” World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297 (1980); Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017).
discussed Cited as authority (rule) The Paper Tigers, Inc. v. Arch Specialty Insurance Company (2×) also: Cited "see"
N.D. Ill. · 2025 · confidence medium
Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017).
cited Cited as authority (rule) International Golden Foods, Inc. v. Saffronia, Inc.
N.D. Ill. · 2025 · confidence medium
Dismiss at 5–7 (citing, inter alia, Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017); Goldberg v. Miller, 874 F. Supp. 874, 877 (N.D.
discussed Cited as authority (rule) Patel v. CBC Pharma HoldCo LLC
N.D. Ill. · 2025 · confidence medium
Minimum contacts exist where “the defendant’s conduct and connection with the forum State are such that he should reasonably anticipate being haled into court there.” World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297 (1980); Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017).
discussed Cited as authority (rule) Mercis B.V. v. The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto
N.D. Ill. · 2025 · confidence medium
Minimum contacts exist where “the defendant’s conduct and connection with the forum State are such that he should reasonably anticipate being haled into court there.” World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297 (1980); Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017).
discussed Cited as authority (rule) Byron v. Stiiizy, Inc.
S.D. Ill. · 2025 · confidence medium
Motion to Dismiss for Lack of Personal Jurisdiction “As a procedural matter, federal courts look to state law in determining the bounds of their jurisdiction over a party.” Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017) (citing FED.
discussed Cited as authority (rule) Naturella USA Ltd. v. BendTec, Inc.
D. Minnesota · 2025 · confidence medium
Illinois employs a long-arm statute which applies the same standard as federal due process: a defendant must have sufficient contacts with the forum state “such that the maintenance of the suit does not offend traditional notions of fair play and substantial justice.” Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017), quoting Int’l Shoe Co. v. Washington, 326 U.S. 310, 316 (1945).
discussed Cited as authority (rule) Naturella USA Ltd. v. BendTec, Inc.
N.D. Ill. · 2025 · confidence medium
Illinois employs a long-arm statute which applies the same standard as federal due process: a defendant must have sufficient contacts with the forum state “such that the maintenance of the suit does not offend traditional notions of fair play and substantial justice.” Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017), quoting Int’l Shoe Co. v. Washington, 326 U.S. 310, 316 (1945).
discussed Cited as authority (rule) Pit Viper, LLC v. The Partnerships and Unincorporated Associations Identified on Schedule A
N.D. Ill. · 2024 · confidence medium
Minimum contacts exist where “the defendant’s conduct and connection with the forum State are such that he should reasonably anticipate being haled into court there.” World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297 (1980); Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017).
cited Cited as authority (rule) Ruthven v. Lazer Spot, Inc.
N.D. Ill. · 2024 · confidence medium
Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017).
discussed Cited as authority (rule) Collectanea J. Limited v. The Partnerships And Unincorporated Associations Identified On Schedule A
N.D. Ill. · 2024 · confidence medium
Minimum contacts exist where “the defendant’s conduct and connection with the forum State are such that he should reasonably anticipate being haled into court there.” World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297 (1980); Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017).
cited Cited as authority (rule) Chase v. Rebecca Fisher Law Firm
N.D. Ind. · 2024 · confidence medium
“The inquiry must focus on ‘the relationship among the defendant, the forum, and the litigation.’” Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017) (quoting Walden, 571 U.S. at 283–84).
discussed Cited as authority (rule) Beattie v. Emerald Expositions
N.D. Ill. · 2024 · confidence medium
Illinois employs a long-arm statute which applies the same standard as federal due process: a defendant must have sufficient contacts with the forum state “such that the maintenance of the suit does not offend traditional notions of fair play and substantial justice.” Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017), quoting Int’l Shoe Co. v. Washington, 326 U.S. 310, 316 (1945).
discussed Cited as authority (rule) Roadget Business Pte. Ltd. v. The Individuals, Corporations, Limited Liability Companies Partnerships, and Unincorporated Associations Identified on Schedule A Hereto
N.D. Ill. · 2024 · confidence medium
Minimum contacts exist where “the defendant’s conduct and connection with the forum State are such that he should reasonably anticipate being haled into court there.” World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297 (1980); Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017).
discussed Cited as authority (rule) Schoeps v. Sompo Holdings, Inc.
N.D. Ill. · 2024 · confidence medium
Minimum contacts exist where “the defendant’s conduct and connection with the forum State are such that he should reasonably anticipate being haled into court there.” World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297 (1980); Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017).
discussed Cited as authority (rule) Shebesh v. Ancestry.com
N.D. Ill. · 2024 · confidence medium
Minimum contacts exist where “the defendant’s conduct and connection with the forum State are such that he should reasonably anticipate being haled into court there.” World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297 (1980); Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017).
discussed Cited as authority (rule) Roadget Business Pte. Ltd. v. The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto
N.D. Ill. · 2024 · confidence medium
Minimum contacts exist where “the defendant’s conduct and connection with the forum State are such that he should reasonably anticipate being haled into court there.” World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297 (1980); Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017).
discussed Cited as authority (rule) Blake v. Celebrity Home Loans, LLC
N.D. Ill. · 2024 · confidence medium
Minimum contacts exist where “the defendant’s conduct and connection with the forum State are such that he should reasonably anticipate being haled into court there.” World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297 (1980); Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017).
discussed Cited as authority (rule) Woodward v. Humana, Inc.
N.D. Ill. · 2024 · confidence medium
The Illinois long-arm statute requires nothing more than the standard for federal due process: that the defendant have sufficient contacts with the forum state “such that the maintenance of the suit does not offend traditional notions of fair play and substantial justice.” Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017) (quoting Int'l Shoe Co. v. Washington, 326 U.S. 310, 316 , 66 S.Ct. 154 , 90 L.Ed. 95 (1945)).
discussed Cited as authority (rule) Theta IP, LLC v. Motorola Mobility LLC
N.D. Ill. · 2024 · confidence medium
Minimum contacts exist where “the defendant’s conduct and connection with the forum State are such that he should reasonably anticipate being haled into court there.” World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297 (1980); Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017).
discussed Cited as authority (rule) Savista, LLC v. GS Labs, LLC
N.D. Ill. · 2024 · confidence medium
Minimum contacts exist where “the defendant’s conduct and connection with the forum State are such that he should reasonably anticipate being haled into court there.” World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297 (1980); Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017).
discussed Cited as authority (rule) HS Wholesale Limited v. HS Global Distribution, LLC
N.D. Ill. · 2024 · confidence medium
Minimum contacts exist where “the defendant’s conduct and connection with the forum State are such that he should reasonably anticipate being haled into court there.” World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297 (1980); Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017).
examined Cited as authority (rule) Spitz v. Starr Indemnity & Liability Company, Inc. (5×) also: Cited "see", Cited "see, e.g."
N.D. Ill. · 2023 · confidence medium
Minimum contacts exist where “the defendant’s conduct and connection with the forum State are such that he should reasonably anticipate being haled into court there.” World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297 (1980); Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017).
cited Cited as authority (rule) K & S Carriers LLC v. Total Quality Logistics LLC
W.D. Wis. · 2023 · confidence medium
Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017).
discussed Cited as authority (rule) Cityzenith Holdings, Inc. v. Liddell
N.D. Ill. · 2023 · confidence medium
Minimum contacts exist where “the defendant’s conduct and connection with the forum State are such that he should reasonably anticipate being haled into court there.” World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297 (1980); Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017).
discussed Cited as authority (rule) Reynolds v. Skyline Real Estate Investments
N.D. Ill. · 2023 · confidence medium
Minimum contacts exist where “the defendant’s conduct and connection with the forum State are such that he should reasonably anticipate being haled into court there.” World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297 (1980); Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017).
discussed Cited as authority (rule) AAA Max 1 Limited v. The Boeing Company
N.D. Ill. · 2023 · confidence medium
Minimum contacts exist where “the defendant’s conduct and connection with the forum State are such that he should reasonably anticipate being haled into court there.” World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297 (1980); Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017).
discussed Cited as authority (rule) Skycoin Global Foundation Limited v. Stephens
N.D. Ill. · 2023 · confidence medium
Minimum contacts exist where “the defendant’s conduct and connection with the forum State are such that he should reasonably anticipate being haled into court there.” World-Wide Volkswagon Corp. v. Woodson, 444 U.S. 286, 297 (1980); Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017).
discussed Cited as authority (rule) Pearson v. Zaehringer
Ill. App. Ct. · 2023 · confidence medium
Brook v. McCormley, 873 F.3d 549, 552-53 (7th Cir. 2017) (citing Advanced Tactical Ordnance Systems, LLC v. Real Action Paintball, Inc., 751 F.3d 796, 801 (7th Cir. 2014)).
cited Cited as authority (rule) Track, Inc. v. Swenson Spreader, LLC
W.D. Wis. · 2023 · confidence medium
Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017).
cited Cited as authority (rule) Eckelberger v. LG Chem America Inc.
S.D. Ill. · 2023 · confidence medium
DISCUSSION “As a procedural matter, federal courts look to state law in determining the bounds of their jurisdiction over a party.” Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017) (citing FED.
discussed Cited as authority (rule) Brewer v. Affinity Development Group
N.D. Ill. · 2022 · confidence medium
Specific jurisdiction, on the other hand, refers to jurisdiction over a defendant in a suit arising out of or related to the defendant’s contacts with the forum; those contacts must be “directly related to the conduct pertaining to the claims asserted.” Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017).
discussed Cited as authority (rule) Bakhtiari v. Doe
N.D. Ill. · 2022 · confidence medium
Minimum contacts exist where “the defendant’s conduct and connection with the forum State are such that he should reasonably anticipate being haled into court there.” World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297 (1980); Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017).
discussed Cited as authority (rule) Reynolds v. Skyline Real Estate Investments
N.D. Ill. · 2022 · confidence medium
Minimum contacts exist where “the defendant’s conduct and connection with the forum State are such that he should reasonably anticipate being haled into court there.” World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297 (1980); Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017).
examined Cited as authority (rule) Diamond Services Management Company LLC v. C&C Jewelry Manufacturing, Inc. (3×) also: Cited "see"
N.D. Ill. · 2022 · confidence medium
Illinois permits its courts to exercise personal jurisdiction up to the limits of the standard for federal due process: that the defendant have sufficient contacts with the forum state “such that the maintenance of the suit does not offend traditional notions of fair play and substantial justice.” Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017) (quoting Int’l Shoe Co. v. Washington, 326 U.S. 310, 316 (1945)); see 735 ILCS 5/2-209(c).
discussed Cited as authority (rule) Carcharadon,LLC v. Askey
N.D. Ill. · 2022 · confidence medium
Minimum contacts exist where “the defendant’s conduct and connection with the forum State are such that he should reasonably anticipate being haled into court there.” World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297 (1980); Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017).
discussed Cited as authority (rule) Carcharadon, LLC v. Ascend Robotics, LLC
N.D. Ill. · 2022 · confidence medium
Minimum contacts exist where “the defendant’s conduct and connection with the forum State are such that he should reasonably anticipate being haled into court there.” World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297 (1980); Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017).
cited Cited as authority (rule) Anthony v. Chromalox, Inc
W.D. Pa. · 2022 · confidence medium
“The inquiry must focus on ‘the relationship among the defendant, the forum, and the litigation.’” Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017) (quoting Walden, 571 U.S. at 283–84).
cited Cited as authority (rule) Anthony v. Chromalox Inc
N.D. Ind. · 2022 · confidence medium
“The inquiry must focus on ‘the relationship among the defendant, the forum, and the litigation.’” Brook v. McCormley, 873 F.3d 549, 552 (7th Cir. 2017) (quoting Walden, 571 U.S. at 283–84).
Retrieving the full opinion text from the archive…
Sherwin A. BROOK, as Trustee of the David North II Trust, Successor to the Assets of Cortina Financial, Inc., Plaintiff-Appellant,
v.
J. Lawrence MCCORMLEY, Et Al., Defendants-Appellees
16-4255.
Court of Appeals for the Seventh Circuit.
Oct 11, 2017.
873 F.3d 549
Merle L. Royce, Attorney, Law Offices of Merle L. Royce,' Chicago, IL, for Plaintiff-Appellant., William .M. Fischbach, III, Attorney, Tiffany & Bosco,' P.A., Phoenix, AZ, Thomas P. McGarry, Attorney, Stephen R. Swofford, Attorney, Hinshaw & Culbertson LLP, Chicago, IL, for Defendants-Appellees.
Bauer, Rovner, Sykes.
Cited by 137 opinions  |  Published  |  civil
1 passage pin-cited by 1 case
Pinpoint authority: bottom 68%
Citer courts: N.D. Illinois (1)
BAUER, Circuit Judge.

Plaintiff-appellant, Sherwin Brook (“Brook”), appeals the district court’s finding that the Northern District of Illinois lacks personal jurisdiction over the defendants-appellees, J. Lawrence McCormley and Tiffany & Bosco, P.A. (collectively, “Defendants”), for a legal malpractice, breach of contract, and breach of fiduciary duty lawsuit. For the reasons set forth below, we affirm.

I. BACKGROUND

Cortina Financial, Inc. (“Cortina”) is a now-dissolved corporation that was wholly-owned by the David North' II Trust (the “Trust”). The beneficiaries of the Trust lived in Illinois when the Trust was established; however, in the mid-1980s, they relocated to Arizona. In 2011, the Trust became an Arizona trust. Brook, an Illinois resident, was the president of Cortina and is the trustee of the Trust. Lawrence McCormley is a resident of Arizona and an attorney at Tiffany & Bosco, a law firm with its principal place of business in Arizona.

In 2001, Brook sought out Tiffany & Bosco to represent Cortina in a lawsuit. The lawsuit arose from a dispute over a ground lease created; when Cortina sold one of four plots of. land-the company owned in Scottsdale, Arizona. The suit was dismissed in 2002. ■ ■ .

In 2005, and again in 2013, Cortina sought additional legal advice from Tiffany & Bosco'to analyze the viability of claims related to the same ground lease under Arizona’s various statutory limitation periods. In 2014, Cortina requested that Tiffany & Bosco initiate a nonjudicial foreclosure on the property. Tiffany & Bosco ultimately decided that the firm’s involvement in the nonjudicial foreclosure would pose conflict of interest issues and declined the opportunity to represent Cortina. Throughout Tiffany & Bosco’s thirteen years representing Cortina, the parties exchanged phone calls and correspondence between Arizona and Illinois, but all in-person meetings occurred in Arizona.

Cortina filed suit against Defendants in the Northern District of Illinois alleging legal malpractice, breach of contract, and breach of fiduciary duty. After the district court requested a jurisdictional statement, Cortina substituted in Brook as the plaintiff through an amended complaint.

The district court dismissed Brook’s amended complaint for lack of personal jurisdiction. The district court acknowledged that Defendants entered into a business relationship with an Illinois plaintiff, but pointed out that the activities were strictly conducted in Arizona. Additionally, the court cited the lack of evidence showing that Defendants reached out to or solicited Cortina, the Trust, or Brook to enter into the relationship. Brook appeals.

II. DISCUSSION

The standard of review for a. dismissal based on lack of personal jurisdiction is de novo. Tamburo v. Dworkin, 601 F.3d 693, 700 (7th Cir. 2010). In order for a district court to bind an individual, the court must have personal jurisdiction over that individual. Ins. Corp. of Ir., Ltd. v. Compagnie des Bauxites de Guinee, 456 U.S. 694, 701, 102 S.Ct. 2099, 72 L.Ed.2d 492 (1982). The plaintiff bears the burden of establishing personal jurisdiction. Cent. States, Se. & Sw. Areas Pension Fund v. Reimer Express World Corp., 230 F.3d 934, 939 (7th Cir. 2000).

As a procedural matter, federal courts look to state law in determining the bounds of their jurisdiction over a party. Fed. R. Civ. P. 4(k)(1)(A); see also Walden v. Fiore, — U.S. —, 134 S.Ct. 1115, 1121, 188 L.Ed.2d 12 (2014). The Illinois long-arm statute permits the court to exercise jurisdiction to the full extent permitted by the Due Process Clause of the Fourteenth Amendment. 735 Ill Comp Stat 5/2-209(c). Thus, the state statutory and federal constitutional requirements merge. Tamburo, 601 F.3d at 700.

The Due Process Clause of the Fourteenth Amendment limits the power of a court to render a judgment over nonresident defendants. World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 291, 100 S.Ct. 559, 62 L.Ed.2d 490 (1980). To determine this constitutional limitation, courts must determine whether the defendant had sufficient “minimum contacts [... ] such that the maintenance of the suit does not offend traditional notions of fair play and substantial justice.” Int’l Shoe Co. v. Wash., 326 U.S. 310, 316, 66 S.Ct. 154, 90 L.Ed. 95 (1945) (quoting Milliken v. Meyer, 311 U.S. 457, 463, 61 S.Ct. 339, 85 L.Ed. 278 (1940)) (internal quotations omitted). While the defendant’s physical presence in the forum State is not required, there must be sufficient minimum contacts such that he or she “should reasonably anticipate being haled into court there.” Burger King Corp. v. Rudzewicz, 471 U.S. 462, 474, 105 S.Ct. 2174, 85 L.Ed.2d 528 (1985) (quoting World-Wide Volkswagen Corp., 444 U.S. at 297, 100 S.Ct. 559).

Jurisdiction over a defendant can be established either through general or specific jurisdiction. Tamburo, 601 F.3d at 701. General jurisdiction looks to the defendant’s “continuous and systematic” contacts with a state, whether or not the action is related to the contacts. Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408, 416, 104 S.Ct. 1868, 80 L.Ed.2d 404 (1984). Here, there is no contention that general jurisdiction is present; so, we will only address specific jurisdiction. Specific jurisdiction “refers to jurisdiction over a defendant in a suit arising out of or related to the defendant’s contacts with the forum.” GCIU-Emp’r Ret. Fund v. Goldfarb Corp., 565 F.3d 1018, 1023 (7th Cir. 2009).

Specific jurisdiction requires a defendant’s contacts with the forum State to be directly related to the conduct pertaining to the claims asserted. Tamburo, 601 F.3d at 702. The mere fact that a defendant’s conduct affects a plaintiff with connections to the forum State is not sufficient to establish jurisdiction. Advanced Tactical Ordnance Sys., LLC v. Real Action Paintball, Inc., 751 F.3d 796, 801 (7th Cir. 2014) (quoting Keeton v. Hustler Magazine, Inc., 465 U.S. 770, 775, 104 S.Ct. 1473, 79 L.Ed.2d 790 (1984)). The inquiry must focus on “the relationship among the defendant, the forum, and the litigation.” Walden, 134 S.Ct, at 1122 (quoting Keeton, 465 U.S. at 775, 104 S.Ct. 1473) (internal quotations omitted). The defendant’s relationship with the plaintiff is not sufficient to create the necessary “minimum contacts.” Walden, 134 S.Ct. at 1123. Rather, “the relationship must arise out of contacts that the defendant himself creates with the forum State,” and “the defendant’s contacts with the forum State itself.” Id. at 1122 (emphasis provided).

We find Brook’s argument based on Illinois’ long-arm statute to be unpersuasive. Brook argues that three enumerated sections in Illinois’ long-arm statute are applicable here; specifically that the transaction involved: (1) “[t]he commission of a tortious act within this State;” (2) “[t]he making or performance of any contract or promise substantially connected with this State;” and (3) “[t]he breach of any fiduciary duty within this State.” 735 Ill Comp Stat 5/2-209(a)(2), (7) and (11). These assertions are based on correspondence from Arizona, telephone calls, the contract governing the attorney-client relationship, attorneys’ fees sent from Illinois, and Brook having felt the injury in Illinois. We find this unpersuasive. Brook attempts to use Defendants’ relationship with himself to establish personal jurisdiction, not the Defendants’ relationship with Illinois.

We find Walden particularly instructive in this case. In Walden, a police officer searched and seized a large sum of cash from two individuals in Georgia before they boarded their flight for Nevada. Walden, 134 S.Ct. at 1119. In an effort to retrieve their property, communications commenced between the two individuals in Nevada and the officer in Georgia. Id. Amongst these communications were phone calls from Nevada, documentation from Nevada, and an affidavit from Georgia showing probable cause to seize the cash. Id. The two individuals filed suit in a district court in Nevada. Id. at 1120. Our Supreme Court found a lack of personal jurisdiction because the officer “never traveled to, conducted activities within, contacted anyone in, or sent anything or anyone to Nevada.” Id. at 1124. The Court held that the district court in Nevada lacked personal jurisdiction over the officer. Id. at 1121.

Here, as in Walden, the tenuous contacts with Illinois are insufficient to establish personal jurisdiction. Defendants in this case never sought out nor conducted business in Illinois, rather Cortina sought out legal services from Defendants. The subject matter of the representation was land in Arizona subject to Arizona law. All business on behalf of Cortina was done in Arizona by an Arizona based law firm with Arizona lawyers. Put quite simply, Brook, a substituted plaintiff, is the only link Defendants have with the forum State. Brook has failed to establish that the district court has personal jurisdiction over Defendants.

III. CONCLUSION

For the forgoing reasons, we AFFIRM the district court’s dismissal for lack of personal jurisdiction.