minimum contacts test in Vermont

2026Co. v. Robertson-Ceco Corp., 84 F.3d 560, 567-68 (2d Cir. 1996) (citations omitted); see also Canaday v. Anthem Companies, Inc., 9 F.4th 392, 400 (6th Cir. 2021) (the contacts relevant to specific personal jurisdiction are claim-specific).

2026Co. v. Robertson-Ceco Corp., 84 F.3d 560, 567-68 (2d Cir. 1996) (citations omitted); see also Canaday v. Anthem Companies, Inc., 9 F.4th 392, 400 (6th Cir. 2021) (the contacts relevant to specific personal jurisdiction are claim-specific).

2005A key consideration of the minimum contacts requirement is whether “‘the defendant’s conduct and connection with the forum State are such that [the defendant] should reasonably anticipate being haled into court there.’” Id. at 276 (quoting World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297 (1980)).

2005The “critical consideration” in determining whether a defendant’s activities satisfy the minimum contacts requirement is whether “‘the defendant’s conduct and connection with the forum State are such that [the defendant] should reasonably anticipate being haled into court there.’” Id. at 276 (quoting World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297 (1980)).

2026Co. v. Robertson-Ceco Corp., 84 F.3d 560, 567-68 (2d Cir. 1996) (citations omitted); see also Canaday v. Anthem Companies, Inc., 9 F.4th 392, 400 (6th Cir. 2021) (the contacts relevant to specific personal jurisdiction are claim-specific).

2026Co. v. Robertson-Ceco Corp., 84 F.3d 560, 567-68 (2d Cir. 1996) (citations omitted); see also Canaday v. Anthem Companies, Inc., 9 F.4th 392, 400 (6th Cir. 2021) (the contacts relevant to specific personal jurisdiction are claim-specific).

1995Burger King further instructs that the application of the minimum contacts rule "will vary with the quality and nature of the defendant's activity, but 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." Id. at 475, 105 S.Ct. at 2183 (quoting Hanson v. Denckla, 357 U.S. 235, 253 , 78 S.Ct. 1228, 1240 , 2 L.Ed.2d 1283 (1958)) (emphasis added).

1995Burger King further instructs that the application of the minimum contacts rule “will vary with the quality and nature of the defendant’s activity, but 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.” Id. at 475 (quoting Hanson v. Denckla, 357 U.S. 235, 253 (1958)) (emphasis added).

1995The critical consideration in determining if defendants’ activities satisfy the minimum contacts requirement is whether “the defendant’s conduct and connection with the forum State are such that [the defendant] should reasonably anticipate being haled into court there.” World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297 (1980); Northern Aircraft, 154 Vt. at 41 , 572 A.2d at 1386 .

1995The critical consideration in determining if defendants’ activities satisfy the minimum contacts requirement is whether “the defendant’s conduct and connection with the forum State are such that [the defendant] should reasonably anticipate being haled into court there.” World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297 (1980); Northern Aircraft, 154 Vt. at 41 , 572 A.2d at 1386 .

2011Subsequently, the Supreme Court’s jurisprudence established the minimum contacts test as the basis for jurisdiction for both in personam, Int’l Shoe, 326 U.S. at 316 , and eventually in rem cases, but continued to exempt “status cases,” recognizing PennoyeP s extension of jurisdiction to “cases involving the personal status of the plaintiff, such as divorce actions, could be adjudicated in the plaintiff’s home State even though the defendant could not be served within that State.” Shaffer v. Heitner, 433 U.S. 186, 201 (1977) (citing Pennoyer, 95 U.S. at 733-35 ).

2011Subsequently, the Supreme Court’s jurisprudence established the minimum contacts test as the basis for jurisdiction for both in personam, Int’l Shoe , 326 U.S. at 316 , and eventually in rem cases, but continued to exempt “status cases,” recognizing Pennoyer ’s extension of jurisdiction to “cases involving the personal status of the plaintiff, such as divorce actions, could be adjudicated in the plaintiff’s home State even though the defendant could not be served within that State.” Shaffer v. Heitner , 433 U.S. 186, 201 (1977) (citing Pennoyer , 95 U.S. at 733-35 ).

2005A key consideration of the minimum contacts requirement is whether “‘the defendant’s conduct and connection with the forum State are such that [the defendant] should reasonably anticipate being haled into court there.’” Id. at 276 (quoting World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297 (1980)).

2005In Dall, for example, the Court held that a party in the business of selling horses has enough conduct in and connection to Vermont to satisfy the minimum contacts requirement where the party had placed more than 100 advertisements in a nationally circulated publication and had held itself out to be a premium horse breeder. 163 Vt. at 275–77.

2005Additionally, “[i]t is essential to a finding of personal jurisdiction that a defendant ‘purposefully avails itself of the privilege of conducting activities within the forum State, thus invoking the benefits and protections of its laws.’” Schwartz v. Frankenhoff, 169 Vt. 287, 293 (1999) (quoting Burger King Corp. v. Rudzewicz, 471 U.S. 462, 475 (1985)).

1995Burger King further instructs that the application of the minimum contacts rule "will vary with the quality and nature of the defendant's activity, but 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." Id. at 475, 105 S.Ct. at 2183 (quoting Hanson v. Denckla, 357 U.S. 235, 253 , 78 S.Ct. 1228, 1240 , 2 L.Ed.2d 1283 (1958)) (emphasis added).

2025See id.; City & Cnty of Honolulu v. Sunoco LP, 537 P.3d 1173 , 1192 (Haw. 2023) (“Because [d]efendants are subject to specific 14 jurisdiction under the minimum contacts test . . . it is not necessary to engage in an effects test analysis as to the first two prongs of the due process inquiry.”), cert denied, __ U.S. __, 145 S. Ct. 1111 (2025) (mem.).

2025But “[t]he effects test . . . does not supplant the traditional minimum contacts test for purposeful availment applicable in contract and tort cases alike.” Louis Vuitton Malletier, S.A. v. Mosseri, 736 F.3d 1339, 1357 (11th Cir. 2013).

2025Accordingly, we apply the traditional minimum-contacts test. 7 must show that the defendant deliberately ‘reached out beyond’ its home—by, for example, ‘exploit[ing] a market’ in the forum State or entering a contractual relationship centered there.” Id. (alteration in original) (quoting Walden v. Fiore, 571 U.S. 277, 285 (2014)). ¶ 18.

2024Because general jurisdiction is not related to the events giving rise to the suit, courts impose a more stringent minimum contacts test, requiring the plaintiff to demonstrate the defendant's “continuous and systematic general business contacts.” Helicopteros, 466 U.S. at 416, 104 S.Ct. at 1873; see, e.g., Grand Entertainment Group, Ltd. v. Star Media Sales, Inc., 988 F.2d 476 , 481 n. 3 (3d Cir.1993); Shute v. Carnival Cruise Lines, 897 F.2d 377 , 380–81 (9th Cir.1990), rev'd on other grounds, 499 U.S. 585 , 111 S.Ct. 1522 , 113 L.Ed.2d 622 (1991); Donatelli v. National Hockey League, 893 F.2

2024Because general jurisdiction is not related to the events giving rise to the suit, courts impose a more stringent minimum contacts test, requiring the plaintiff to demonstrate the defendant's “continuous and systematic general business contacts.” Helicopteros, 466 U.S. at 416, 104 S.Ct. at 1873; see, e.g., Grand Entertainment Group, Ltd. v. Star Media Sales, Inc., 988 F.2d 476 , 481 n. 3 (3d Cir.1993); Shute v. Carnival Cruise Lines, 897 F.2d 377 , 380–81 (9th Cir.1990), rev'd on other grounds, 499 U.S. 585 , 111 S.Ct. 1522 , 113 L.Ed.2d 622 (1991); Donatelli v. National Hockey League, 893 F.2

2013See Chloe v. Queen Bee of Beverly Hills, LLC, 616 F.3d 158, 164 (2d Cir. 2010) (noting distinction between specific and general jurisdiction for purposes of the minimum contacts inquiry). 2 Hoplite asserts in its motion that this language appears in its Exhibit A. It does not, nor does it appear elsewhere in Hoplite’s exhibits.

2012E.g., Consulting Eng’rs Corp. v. Geometric Ltd., 561 F.3d 273, 280 (4th Cir. 2009) (noting that Calder’s “effects test does not supplant the minimum contacts analysis, but rather informs it”); IMO Indus., Inc. v. Kiekert AG, 155 F.3d 254, 265 (3d Cir. 1998) (“[W]e . . . agree with the conclusion reached by the First, Fourth, Fifth, Eighth, Ninth, and Tenth Circuits that jurisdiction under Calder requires more than a finding that the harm caused by the defendant’s intentional tort is primarily felt within the forum.”); Drayton Enterprises, L.L.C. v. Dunker, 142 F. Supp. 2d 1177, 1185 (D.N.D. 20

2012E.g., Consulting Eng’rs Corp. v. Geometric Ltd., 561 F.3d 273, 280 (4th Cir. 2009) (noting that Calder’s “effects test does not supplant the minimum contacts analysis, but rather informs it”); IMO Indus., Inc. v. Kiekert AG, 155 F.3d 254, 265 (3d Cir. 1998) (“[W]e . . . agree with the conclusion reached by the First, Fourth, Fifth, Eighth, Ninth, and Tenth Circuits that jurisdiction under Calder requires more than a finding that the harm caused by the defendant’s intentional tort is primarily felt within the forum.”); Drayton Enterprises, L.L.C. v. Dunker, 142 F. Supp. 2d 1177, 1185 (D.N.D. 20

2012E.g., Consulting Eng’rs Corp. v. Geometric Ltd., 561 F.3d 273, 280 (4th Cir. 2009) (noting that Calder’s “effects test does not supplant the minimum contacts analysis, but rather informs it”); IMO Indus., Inc. v. Kiekert AG, 155 F.3d 254, 265 (3d Cir. 1998) (“[W]e . . . agree with the conclusion reached by the First, Fourth, Fifth, Eighth, Ninth, and Tenth Circuits that jurisdiction under Calder requires more than a finding that the harm caused by the defendant’s intentional tort is primarily felt within the forum.”); Drayton Enterprises, L.L.C. v. Dunker, 142 F. Supp. 2d 1177, 1185 (D.N.D. 20

2005Additionally, “[i]t is essential to a finding of personal jurisdiction that a defendant ‘purposefully avails itself of the privilege of conducting activities within the forum State, thus invoking the benefits and protections of its laws.’” Schwartz v. Frankenhoff, 169 Vt. 287, 293 (1999) (quoting Burger King Corp. v. Rudzewicz, 471 U.S. 462, 475 (1985)).