minimum contacts test (Missouri) · Go Syfert
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minimum contacts test in Missouri

18 Missouri opinions name it 2 courts 1982–2023 2 in the last five years

The cases below were cited by Missouri courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (15)

CaseFollowedCited
Crouch v. Crouchgreen
mo · 1982 · cited in 5 Missouri opinions naming this issue, 1984–2023
2 sentences

2023“Rule 54.06(b) mandates compliance with the minimum contacts test by requiring that one whom the state would subject to an in personam judgment for maintenance, support, attorney’s fees, suit money, or disposition of marital property must have ‘lived in lawful marriage within this state.’” Crouch v. Crouch, 641 S.W.2d 86, 89 (Mo. banc 1982).

2012This rule “mandates compliance with the minimum contacts test by requiring that one whom the state would subject to an in personam judgment for maintenance, support, attorney’s fees, suit money, or disposition of marital property must have ‘lived in lawful marriage within this state.’ ” Crouch v. Crouch, 641 S.W.2d 86, 89 (Mo. banc 1982).

45
Bryant v. Smith Interior Design Group, Inc.green
mo · 2010 · cited in 4 Missouri opinions naming this issue, 2011–2021
2 sentences

2021When evaluating minimum contacts, our inquiry focuses on whether there is “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.” Bryant, 310 S.W.3d at 232 (internal quotations and citation omitted).

2013Where sufficiently significant to a particular cause of action, the mailing of documents into a state has been held adequate to provide the minimum contacts necessary for a court to exercise personal jurisdiction. 310 S.W.3d at 235 n. 6 (citation omitted).

24
World-Wide Volkswagen Corp. v. Woodsongreen
scotus · 1980 · cited in 2 Missouri opinions naming this issue, 2010–2021
2 sentences

2021Moreover, under the minimum contacts analysis, it is essential that “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).

2010Under the minimum contacts analysis it is essential that “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 , 100 S.Ct. 559 , 62 L.Ed.2d 490 (1980).

12
Chromalloy American Corp. v. Elyria Foundry Co.green
mo · 1997 · cited in 2 Missouri opinions naming this issue, 2001–2008
2 sentences

2008Corp., 955 S.W.2d at 4 (citation omitted). “[T]o establish minimum contacts within the forum state, a plaintiff must show that the defendant has taken some act by which it purposefully avails itself of the privilege of conducting business within the forum state.” Wilson Tool & Die, Inc. v. TBDN-Tenn. Co., 237 S.W.3d 611, 616 (Mo.App.2007) (citing Burger King Corp., 471 U.S. at 475-76 , 105 S.Ct. 2174 ).

2001The minimum contacts test is not applied mechanically; rather, “the facts of each case must be weighed to determine whether the requisite ‘affiliating circumstances’ are present.” Chromalloy, 955 S.W.2d at 5 (quoting Dillaplain v. Lite Ind., Inc., 788 S.W.2d 530, 534 (Mo.App.1990)).

12
Thompson v. Thompsongreen
mo · 1983 · cited in 2 Missouri opinions naming this issue, 1984–1998
2 sentences

1998Section 506.500.2 mandates compliance with the minimum contacts test by requiring that one whom the state would subject to an in personam judgment for child support must have “lived in lawful marriage within this state.” Thompson v. Thompson, 657 S.W.2d at 631 (citing Rule 54.06(b)).

1998Section 506.500.2 mandates compliance with the minimum contacts test by requiring that one whom the state would subject to an in personam judgment for child support must have “lived in lawful marriage within this state.” Thompson v. Thompson, 657 S.W.2d at 631 (citing Rule 54.06(b)).

12
Lebel v. Everglades Marina, Inc.green
nj · 1989 · cited in 1 Missouri opinions naming this issue, 2010–2010
2 sentences

2010The Eighth Circuit held that by “purposely directing their fraudulent communications at residents of Nebraska, the defendants should have realized that the brunt of the harm would be felt there ... and they should have reasonably anticipated being haled into court there.” Id. at 943 ; accord, Lewis v. Fresne, 252 F.3d 352, 359 (5th Cir.2001) (“The 'actual content’ of [the defendants’] communications to [the plaintiff] shows purposeful availment of the benefits and protections of Texas law”); Lebel v. Everglades Marina, Inc., 115 N.J. 317 , 558 A.2d 1252, 1257 (1989) (“In this case, defendant’s

2010The Eighth Circuit held that by “purposely directing their fraudulent communications at residents of Nebraska, the defendants should have realized that the brunt of the harm would be felt there ... and they should have reasonably anticipated being haled into court there.” Id. at 943 ; accord, Lewis v. Fresne, 252 F.3d 352, 359 (5th Cir.2001) (“The 'actual content’ of [the defendants’] communications to [the plaintiff] shows purposeful availment of the benefits and protections of Texas law”); Lebel v. Everglades Marina, Inc., 115 N.J. 317 , 558 A.2d 1252, 1257 (1989) (“In this case, defendant’s

11
Michael P. Lewis v. David M. Fresne Lowell Farkas Robert A. Young Rosenfeld, Bernstein & Tannenhauser LLP Eric P. Rosenfeldgreen
ca5 · 2001 · cited in 1 Missouri opinions naming this issue, 2010–2010
1 sentence

2010The Eighth Circuit held that by “purposely directing their fraudulent communications at residents of Nebraska, the defendants should have realized that the brunt of the harm would be felt there ... and they should have reasonably anticipated being haled into court there.” Id. at 943 ; accord, Lewis v. Fresne, 252 F.3d 352, 359 (5th Cir.2001) (“The 'actual content’ of [the defendants’] communications to [the plaintiff] shows purposeful availment of the benefits and protections of Texas law”); Lebel v. Everglades Marina, Inc., 115 N.J. 317 , 558 A.2d 1252, 1257 (1989) (“In this case, defendant’s

11
Shrout v. Thorsengreen
ala · 1985 · cited in 1 Missouri opinions naming this issue, 2010–2010
1 sentence

2010The Eighth Circuit held that by “purposely directing their fraudulent communications at residents of Nebraska, the defendants should have realized that the brunt of the harm would be felt there ... and they should have reasonably anticipated being haled into court there.” Id. at 943 ; accord, Lewis v. Fresne, 252 F.3d 352, 359 (5th Cir.2001) (“The 'actual content’ of [the defendants’] communications to [the plaintiff] shows purposeful availment of the benefits and protections of Texas law”); Lebel v. Everglades Marina, Inc., 115 N.J. 317 , 558 A.2d 1252, 1257 (1989) (“In this case, defendant’s

11
State Ex Rel. Nixon v. Beer Nuts, Ltd.green
moctapp · 2000 · cited in 1 Missouri opinions naming this issue, 2010–2010
1 sentence

2010Nixon v. Beer Nuts, Ltd.., 29 S.W.3d 828, 834 (Mo.App. 2000).

11
Wilson Tool & Die, Inc. v. TBDN-Tennessee Co.green
moctapp · 2007 · cited in 1 Missouri opinions naming this issue, 2008–2008
1 sentence

2008Corp., 955 S.W.2d at 4 (citation omitted). “[T]o establish minimum contacts within the forum state, a plaintiff must show that the defendant has taken some act by which it purposefully avails itself of the privilege of conducting business within the forum state.” Wilson Tool & Die, Inc. v. TBDN-Tenn. Co., 237 S.W.3d 611, 616 (Mo.App.2007) (citing Burger King Corp., 471 U.S. at 475-76 , 105 S.Ct. 2174 ).

11
Beckers v. Seckgreen
moctapp · 2000 · cited in 1 Missouri opinions naming this issue, 2001–2001
1 sentence

2001“Random, fortuitous or attenuated contacts with the forum state cannot create jurisdiction.” Beckers v. Seek, 14 S.W.3d 139, 143 (Mo.App.2000) (citation omitted).

11
Dillaplain v. Lite Industries, Inc.green
moctapp · 1990 · cited in 1 Missouri opinions naming this issue, 2001–2001
1 sentence

2001The minimum contacts test is not applied mechanically; rather, “the facts of each case must be weighed to determine whether the requisite ‘affiliating circumstances’ are present.” Chromalloy, 955 S.W.2d at 5 (quoting Dillaplain v. Lite Ind., Inc., 788 S.W.2d 530, 534 (Mo.App.1990)).

11
TSE Supply Co. v. Cumberland Natural Gas Co.green
moctapp · 1983 · cited in 1 Missouri opinions naming this issue, 1993–1993
1 sentence

1993Gering, 540 S.W.2d at 35 ; TSE Supply Co. v. Cumberland Natural Gas Co., 648 S.W.2d 169, 170 (Mo.App.1983).

11
Breiner Equipment Co. v. Dynaquip, Inc.green
moed · 1982 · cited in 1 Missouri opinions naming this issue, 1985–1985
1 sentence

1985(Emphasis added.) The minimum contacts requirement was discussed in the context of Missouri law in Breiner Equipment Co. v. Dynaquip, Inc., 539 F.Supp. 204, 206 (E.D.Mo.1982), where the court found the contacts insufficient to exercise personal jurisdiction.

11
State Ex Rel. Sperandio v. Clymergreen
mo · 1979 · cited in 1 Missouri opinions naming this issue, 1982–1982
1 sentence

1982Sperandio v. Clymer, 581 S.W.2d 377, 381 (Mo.banc 1979).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Missouri. Read the followed side critically anyway.

Also cited on this issue (9)

CaseCitedYears
Burger King Corp. v. Rudzewicz green
scotus · 1985
2 sentences

2015This minimum contacts analysis provides a defendant with predictability by “ensuring] that a defendant will not be haled into a jurisdiction solely as the result of random, fortuitous, or attenuated contacts.” Burger King, 471 U.S. at 475 , 105 S.Ct. 2174 (internal quotations omitted).

2015This minimum contacts analysis provides a defendant with predictability by “ensuring] that a defendant will not be haled into a jurisdiction solely as the result of random, fortuitous, or attenuated contacts.” Burger King, 471 U.S. at 475 , 105 S.Ct. 2174 (internal quotations omitted).

22008–2015
Shaffer v. Heitner green
scotus · 1977
2 sentences

2009The standard for determining whether an exercise of jurisdiction over the interests of persons is consistent with the Due Process Clause is the minimum contacts standard elucidated in International Shoe." 433 U.S. at 207 , 97 S.Ct. 2569 (citations and internal quotes omitted.). 5 .

2009The standard for determining whether an exercise of jurisdiction over the interests of persons is consistent with the Due Process Clause is the minimum contacts standard elucidated in International Shoe." 433 U.S. at 207 , 97 S.Ct. 2569 (citations and internal quotes omitted.). 5 .

21982–2009
International Shoe Co. v. Washington green
scotus · 1945
2 sentences

1998The minimum contacts requirement to “ensure traditional notions of fair play and substantial justice” dates to International Shoe Co. v. Washington, 326 U.S. 310 , 66 S.Ct. 154 , 90 L.Ed. 95 (1945), when the Supreme Court held that: [d]ue process requires only that in order to subject a defendant to a judgment in per-sonam, if he be not present within the territory of the forum, he have certain minimum contacts with it such that the maintenance of the suit does not offend “traditional notions of fair play and substantial justice.” Id. at 316 , 66 S.Ct. at 158 (quoting Milliken v. Meyer, 311 U.

1998The minimum contacts requirement to “ensure traditional notions of fair play and substantial justice” dates to International Shoe Co. v. Washington, 326 U.S. 310 , 66 S.Ct. 154 , 90 L.Ed. 95 (1945), when the Supreme Court held that: [d]ue process requires only that in order to subject a defendant to a judgment in per-sonam, if he be not present within the territory of the forum, he have certain minimum contacts with it such that the maintenance of the suit does not offend “traditional notions of fair play and substantial justice.” Id. at 316 , 66 S.Ct. at 158 (quoting Milliken v. Meyer, 311 U.

21982–1998
Commercial Design v. Dean/Dale & Dean Architects green
moed · 1984
1 sentence

2013Under these circumstances it is entirely fair to require defendant to defend a lawsuit in Missouri arising out of the alleged breach of said contract.”- Id. at 893 . 6 Although we are not aware of any Missouri addressing the precise factual eir- cumstances of this case, decisions in other jurisdictions have held that the minimum contacts test is satisfied where an out-of-state defendant solicits the services of a forum-state attorney, even if (as here), the out-of-state defendant never physically enters the forum state as part of the arrangement. 7 The courts have exercised personal jurisdicti

12013–2013
Oriental Trading Co., Inc., a Nebraska Corporation v. Sam G. Firetti Bing Ran green
ca8 · 2001
1 sentence

2010The Eighth Circuit held that by “purposely directing their fraudulent communications at residents of Nebraska, the defendants should have realized that the brunt of the harm would be felt there ... and they should have reasonably anticipated being haled into court there.” Id. at 943 ; accord, Lewis v. Fresne, 252 F.3d 352, 359 (5th Cir.2001) (“The 'actual content’ of [the defendants’] communications to [the plaintiff] shows purposeful availment of the benefits and protections of Texas law”); Lebel v. Everglades Marina, Inc., 115 N.J. 317 , 558 A.2d 1252, 1257 (1989) (“In this case, defendant’s

12010–2010
Milliken v. Meyer green
scotus · 1941
2 sentences

1998The minimum contacts requirement to “ensure traditional notions of fair play and substantial justice” dates to International Shoe Co. v. Washington, 326 U.S. 310 , 66 S.Ct. 154 , 90 L.Ed. 95 (1945), when the Supreme Court held that: [d]ue process requires only that in order to subject a defendant to a judgment in per-sonam, if he be not present within the territory of the forum, he have certain minimum contacts with it such that the maintenance of the suit does not offend “traditional notions of fair play and substantial justice.” Id. at 316 , 66 S.Ct. at 158 (quoting Milliken v. Meyer, 311 U.

1998The minimum contacts requirement to “ensure traditional notions of fair play and substantial justice” dates to International Shoe Co. v. Washington, 326 U.S. 310 , 66 S.Ct. 154 , 90 L.Ed. 95 (1945), when the Supreme Court held that: [d]ue process requires only that in order to subject a defendant to a judgment in per-sonam, if he be not present within the territory of the forum, he have certain minimum contacts with it such that the maintenance of the suit does not offend “traditional notions of fair play and substantial justice.” Id. at 316 , 66 S.Ct. at 158 (quoting Milliken v. Meyer, 311 U.

11998–1998
State Ex Rel. Bank of Gering v. Schoenlaub green
mo · 1976
1 sentence

1993Gering, 540 S.W.2d at 35 ; TSE Supply Co. v. Cumberland Natural Gas Co., 648 S.W.2d 169, 170 (Mo.App.1983).

11993–1993
Kulko v. Superior Court of Cal., City and County of San Francisco green
scotus · 1978
2 sentences

1987In Kulko v. Superior Court of California, 436 U.S. 84 , 98 S.Ct. 1690 , 56 L.Ed.2d 132 (1978), the court rejected the state court conclusion that where a nonresident defendant has caused an effect in the State by an act or omission outside the State, personal jurisdiction over the defendant arising from that effect may be exercised wherever “reasonable.” In assessing the application of the minimum contacts test the facts in each case must be weighed to determine whether the requisite “affiliating circumstances” found missing in Hanson v. Denckla are present.

1987In Kulko v. Superior Court of California, 436 U.S. 84 , 98 S.Ct. 1690 , 56 L.Ed.2d 132 (1978), the court rejected the state court conclusion that where a nonresident defendant has caused an effect in the State by an act or omission outside the State, personal jurisdiction over the defendant arising from that effect may be exercised wherever “reasonable.” In assessing the application of the minimum contacts test the facts in each case must be weighed to determine whether the requisite “affiliating circumstances” found missing in Hanson v. Denckla are present.

11987–1987
Hanson v. Denckla green
scotus · 1958
2 sentences

1982The minimum-contacts standard in International Shoe Co. v. Washington, 326 U.S. 310 , 66 S.Ct. 154 , 90 L.Ed. 95 (1945) supposes a relationship among the defendant, the forum, and the litigation, Shaffer v. Heitner, supra, 433 U.S. at 204 , 97 S.Ct. at 2579 , and requires, among other things, “... some act by which the defendant purposefully avails [him]self of the privilege of conducting activities within the forum State .... ” Hanson v. Denckla, 357 U.S. 235, 253 , 78 S.Ct. 1228, 1239 , 2 L.Ed.2d 1283 (1958); and see: State ex rel.

1982The minimum-contacts standard in International Shoe Co. v. Washington, 326 U.S. 310 , 66 S.Ct. 154 , 90 L.Ed. 95 (1945) supposes a relationship among the defendant, the forum, and the litigation, Shaffer v. Heitner, supra, 433 U.S. at 204 , 97 S.Ct. at 2579 , and requires, among other things, “... some act by which the defendant purposefully avails [him]self of the privilege of conducting activities within the forum State .... ” Hanson v. Denckla, 357 U.S. 235, 253 , 78 S.Ct. 1228, 1239 , 2 L.Ed.2d 1283 (1958); and see: State ex rel.

11982–1982

Statutes the citing opinions construe

MO § Mo. Rev. Stat. § 506.500 (8)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 629 (1975–2026) CT 85 (1983–2021) CA 77 (1958–2026) IL 74 (1975–2026) FL 55 (1962–2026) NC 53 (1978–2025) NJ 48 (1964–2025) OH 42 (1982–2026) NY 36 (1964–2024) PA 32 (1979–2026) DE 30 (1978–2026) MN 26 (1976–2026) CO 26 (1975–2022) IA 26 (1983–2023) WA 21 (1971–2026) AZ 21 (1981–2024) AL 21 (1986–2024) TN 20 (1981–2023) MO 18 (1982–2023) MD 18 (1978–2024) ME 15 (1995–2022) VT 15 (1979–2026) OK 13 (1973–2014) GA 13 (1980–2025) OR 13 (1982–2025) MI 12 (1974–2025) SC 11 (1985–2022) MA 10 (1983–2024) RI 9 (1981–2016) NM 9 (1986–2020) WI 9 (1997–2020) LA 8 (1971–2009) UT 7 (1990–2019) IN 7 (1982–2017) KS 7 (1980–2022) SD 6 (2005–2025) WV 6 (1981–2015) VA 6 (1977–2015) NE 6 (2005–2025) MS 6 (1984–2022) NV 5 (1998–2022) ID 5 (1977–2021) MT 4 (1982–2009) DC 4 (1968–2001) NH 4 (1987–2025) AR 3 (1994–2013) AK 3 (2018–2024) HI 3 (1996–2024) ND 3 (1980–1991) KY 2 (1980–2002)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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