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13 Oregon opinions name it 3 courts 1982–2025 4 in the last five years
The cases below were cited by Oregon 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.
| Case | Followed | Cited |
|---|---|---|
Burger King Corp. v. Rudzewiczgreen2 sentences2023Burger King Corp., 471 US at 475-76 (internal quotation marks omitted). 2013See Burger King, 471 US at 472-73 ; Helicopteros, 466 US at 414 ; see also Kulko v. California Superior Court, 436 US 84, 92 , 98 S Ct 1690 , 56 L Ed 2d 132 (1978) (in applying the minimum contacts test, “the facts of each case must be weighed to determine whether the requisite ‘affiliating circumstances’ are present”). | 3 | 3 |
International Shoe Co. v. Washingtongreen2 sentences1999Although neither party mentions this point, in Rescue Technology, Inc. v. Claw, Inc., 153 Or App 190, 194 , 956 P2d 1010 (1998), we said that “since Shaffer v. Heitner, 433 US 186 , 97 S Ct 2569 , 53 L Ed 2d 683 (1977), the United States Supreme Court has made the exercise of in rem jurisdiction subject to the minimum contacts test of International Shoe Co. v. Washington, 326 US 310 , 66 S Ct 154 , 90 L Ed 95 (1945), that previously applied solely to in personam jurisdiction.” That statement should not be misunderstood. 1999Although neither party mentions this point, in Rescue Technology, Inc. v. Claw, Inc., 153 Or App 190, 194 , 956 P2d 1010 (1998), we said that “since Shaffer v. Heitner, 433 US 186 , 97 S Ct 2569 , 53 L Ed 2d 683 (1977), the United States Supreme Court has made the exercise of in rem jurisdiction subject to the minimum contacts test of International Shoe Co. v. Washington, 326 US 310 , 66 S Ct 154 , 90 L Ed 95 (1945), that previously applied solely to in personam jurisdiction.” That statement should not be misunderstood. | 1 | 4 |
Shaffer v. Heitnergreen2 sentences1999Although neither party mentions this point, in Rescue Technology, Inc. v. Claw, Inc., 153 Or App 190, 194 , 956 P2d 1010 (1998), we said that “since Shaffer v. Heitner, 433 US 186 , 97 S Ct 2569 , 53 L Ed 2d 683 (1977), the United States Supreme Court has made the exercise of in rem jurisdiction subject to the minimum contacts test of International Shoe Co. v. Washington, 326 US 310 , 66 S Ct 154 , 90 L Ed 95 (1945), that previously applied solely to in personam jurisdiction.” That statement should not be misunderstood. 1999Although neither party mentions this point, in Rescue Technology, Inc. v. Claw, Inc., 153 Or App 190, 194 , 956 P2d 1010 (1998), we said that “since Shaffer v. Heitner, 433 US 186 , 97 S Ct 2569 , 53 L Ed 2d 683 (1977), the United States Supreme Court has made the exercise of in rem jurisdiction subject to the minimum contacts test of International Shoe Co. v. Washington, 326 US 310 , 66 S Ct 154 , 90 L Ed 95 (1945), that previously applied solely to in personam jurisdiction.” That statement should not be misunderstood. | 1 | 3 |
State Ex Rel. Jones v. Crookhamgreen2 sentences2025See Dreher, 162 Or App at 651 (finding minimum contacts were not established where “the payment of money by mail to an Oregon resident and related communications [were] the sum and substance of defendants’ contacts”); *616 see also State ex rel Jones v. Crookham, 296 Or 735, 742 , 681 P2d 103 (1984) (“[T]he act of making monthly payments to an Oregon plaintiff is insufficient to require a non-resident to litigate a contract action in Oregon.”). 2025See Dreher, 162 Or App at 651 (finding minimum contacts were not established where “the payment of money by mail to an Oregon resident and related communications [were] the sum and substance of defendants’ contacts”); *616 see also State ex rel Jones v. Crookham, 296 Or 735, 742 , 681 P2d 103 (1984) (“[T]he act of making monthly payments to an Oregon plaintiff is insufficient to require a non-resident to litigate a contract action in Oregon.”). | 1 | 2 |
North Carolina Dept. of Revenue v. Kimberley Rice Kaestner 1992 Family Trustgreen2 sentences2021Ultimately, only those who derive benefits and protection from associating with a State should have obligations to the State in question.” Id. at ___, 139 S Ct at 2220 (internal quotation marks and citation omitted). 2020The first step, the minimum contacts inquiry, “is flexible and focuses on the reasonableness of the government’s action.” Id. | 1 | 2 |
Dreher v. Smithsongreen1 sentence2025See Dreher, 162 Or App at 651 (finding minimum contacts were not established where “the payment of money by mail to an Oregon resident and related communications [were] the sum and substance of defendants’ contacts”); *616 see also State ex rel Jones v. Crookham, 296 Or 735, 742 , 681 P2d 103 (1984) (“[T]he act of making monthly payments to an Oregon plaintiff is insufficient to require a non-resident to litigate a contract action in Oregon.”). | 1 | 1 |
Willemsen v. Invacare Corporationgreen1 sentence2020See 352 Or at 196 (citing Justice Breyer’s opinion concurring in the judgment in Nicastro). posited in Asahi, taxpayer’s exclusively direct interactions with its Oregon customers fulfill that requirement. | 1 | 1 |
Asahi Metal Industry Co. v. Superior Court of Cal., Solano Cty.green1 sentence2020See id., 480 US at 106 (Asahi sold 100,000 to 500,000 valve stems to distributor, which sold 20 percent of that stock into California). 17 Taxpayer’s sales also dramatically exceeded the approximately $30,929 that defendant China Terminal & Electric Corp. received from selling 1,102 battery chargers into Oregon over a two-year period, amounts that the Oregon Supreme Court found sufficient to satisfy the minimum contacts requirement in Willemsen. | 1 | 1 |
J. McIntyre Machinery, Ltd. v. Nicastrogreen1 sentence2020See id., 480 US at 106 (Asahi sold 100,000 to 500,000 valve stems to distributor, which sold 20 percent of that stock into California). 17 Taxpayer’s sales also dramatically exceeded the approximately $30,929 that defendant China Terminal & Electric Corp. received from selling 1,102 battery chargers into Oregon over a two-year period, amounts that the Oregon Supreme Court found sufficient to satisfy the minimum contacts requirement in Willemsen. | 1 | 1 |
Kulko v. Superior Court of Cal., City and County of San Franciscogreen2 sentences2013See Burger King, 471 US at 472-73 ; Helicopteros, 466 US at 414 ; see also Kulko v. California Superior Court, 436 US 84, 92 , 98 S Ct 1690 , 56 L Ed 2d 132 (1978) (in applying the minimum contacts test, “the facts of each case must be weighed to determine whether the requisite ‘affiliating circumstances’ are present”). 2013See Burger King, 471 US at 472-73 ; Helicopteros, 466 US at 414 ; see also Kulko v. California Superior Court, 436 US 84, 92 , 98 S Ct 1690 , 56 L Ed 2d 132 (1978) (in applying the minimum contacts test, “the facts of each case must be weighed to determine whether the requisite ‘affiliating circumstances’ are present”). | 1 | 1 |
Rush v. Savchukgreen2 sentences1982It is consistent with the United States Supreme Court’s later description of the rationale of the minimum contacts test being “the relationship among the defendant, the forum, and the litigation.” Rush v. Savchuk, 444 US 320, 327 , 100 S Ct 571 , 62 L Ed 2d 516, 524 (1980), quoting Shaffer v. Heitner, 433 US 186, 204 , 97 S Ct 2569 , 53 L Ed 2d 683, 698 (1977). 1982It is consistent with the United States Supreme Court’s later description of the rationale of the minimum contacts test being “the relationship among the defendant, the forum, and the litigation.” Rush v. Savchuk, 444 US 320, 327 , 100 S Ct 571 , 62 L Ed 2d 516, 524 (1980), quoting Shaffer v. Heitner, 433 US 186, 204 , 97 S Ct 2569 , 53 L Ed 2d 683, 698 (1977). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Oregon. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Reeves v. Chem Industrial Company
green
2 sentences2014In any action, whether arising within or without this state, against a defendant who when the action is commenced: «}}? i}i % ‡ “A(5) Has expressly consented to the exercise of personal jurisdiction over such defendant.” (Boldface in original; emphasis added.) In moving to dismiss plaintiffs’ complaint on the basis of lack of personal jurisdiction, defendants contended in the trial court that the relevant contractual provisions— which they describe as choice of law provisions — do not reflect their express consent to personal jurisdiction in Oregon. 13 In addition, they argued that “a choice o 2014In any action, whether arising within or without this state, against a defendant who when the action is commenced: «}}? i}i % ‡ “A(5) Has expressly consented to the exercise of personal jurisdiction over such defendant.” (Boldface in original; emphasis added.) In moving to dismiss plaintiffs’ complaint on the basis of lack of personal jurisdiction, defendants contended in the trial court that the relevant contractual provisions— which they describe as choice of law provisions — do not reflect their express consent to personal jurisdiction in Oregon. 13 In addition, they argued that “a choice o | 1 | 2014–2014 |
The Bremen v. Zapata Off-Shore Co.
red
2 sentences2014In any action, whether arising within or without this state, against a defendant who when the action is commenced: «}}? i}i % ‡ “A(5) Has expressly consented to the exercise of personal jurisdiction over such defendant.” (Boldface in original; emphasis added.) In moving to dismiss plaintiffs’ complaint on the basis of lack of personal jurisdiction, defendants contended in the trial court that the relevant contractual provisions— which they describe as choice of law provisions — do not reflect their express consent to personal jurisdiction in Oregon. 13 In addition, they argued that “a choice o 2014In any action, whether arising within or without this state, against a defendant who when the action is commenced: «}}? i}i % ‡ “A(5) Has expressly consented to the exercise of personal jurisdiction over such defendant.” (Boldface in original; emphasis added.) In moving to dismiss plaintiffs’ complaint on the basis of lack of personal jurisdiction, defendants contended in the trial court that the relevant contractual provisions— which they describe as choice of law provisions — do not reflect their express consent to personal jurisdiction in Oregon. 13 In addition, they argued that “a choice o | 1 | 2014–2014 |
Helicopteros Nacionales De Colombia, S. A. v. Hall
green
1 sentence2013See Burger King, 471 US at 472-73 ; Helicopteros, 466 US at 414 ; see also Kulko v. California Superior Court, 436 US 84, 92 , 98 S Ct 1690 , 56 L Ed 2d 132 (1978) (in applying the minimum contacts test, “the facts of each case must be weighed to determine whether the requisite ‘affiliating circumstances’ are present”). | 1 | 2013–2013 |
Perkins v. BARTLETT CONST. CO., INC.
neutral
2 sentences2001Defendants also rely on Perkins v. Bartlett Construction Co., Inc., 57 Or App 817 , 646 P2d 672 (1982). 2001Defendants also rely on Perkins v. Bartlett Construction Co., Inc., 57 Or App 817 , 646 P2d 672 (1982). | 1 | 2001–2001 |
Horn v. Seacatcher Fisheries, Inc.
neutral
1 sentence2001We said that, for purposes of the “minimum contacts” test, “[ijndeed, those activities are closely analogous to the advertising and solicitation activities that established 'purposeful direction’ in [Circus Circus Reno].” Horn, 128 Or App at 588 . 8 Similarly, Broan’s extensive solicitation in Oregon of plaintiff in this case is sufficient to demonstrate that Broan purposefully directed her hiring activities to an Oregon resident, and her telephonic recruitment activities satisfy the first prong of the minimum contacts analysis. | 1 | 2001–2001 |
State Ex Rel. La Manufacture Francaise Des Pneumatiques Michelin v. Wells
green
2 sentences2001State ex rel Michelin v. Wells, 294 Or 296, 303 , 657 P2d 207 (1982). 2001State ex rel Michelin v. Wells, 294 Or 296, 303 , 657 P2d 207 (1982). | 1 | 2001–2001 |
State Ex Rel. Circus Circus Reno, Inc. v. Pope
green
1 sentence2001As the court said in Circus Circus Reno, “ORCP 4 L means, in practice, that an Oregon court has jurisdiction to the limits of due process under the Fourteenth Amendment; the limits are ‘an issue of federal law to be decided pursuant to the controlling decisions of the *88 United States Supreme Court.’ ” 317 Or at 156 (quoting State ex rel Jones v. Crookham, 296 Or 735, 742 , 681 P2d 103 (1984) (Linde, J., concurring)). | 1 | 2001–2001 |
Sutherland v. Brennan
green
1 sentence1999Sutherland, 321 Or at 530 . | 1 | 1999–1999 |
Rescue Technology, Inc. v. Claw, Inc.
neutral
2 sentences1999Although neither party mentions this point, in Rescue Technology, Inc. v. Claw, Inc., 153 Or App 190, 194 , 956 P2d 1010 (1998), we said that “since Shaffer v. Heitner, 433 US 186 , 97 S Ct 2569 , 53 L Ed 2d 683 (1977), the United States Supreme Court has made the exercise of in rem jurisdiction subject to the minimum contacts test of International Shoe Co. v. Washington, 326 US 310 , 66 S Ct 154 , 90 L Ed 95 (1945), that previously applied solely to in personam jurisdiction.” That statement should not be misunderstood. 1999Although neither party mentions this point, in Rescue Technology, Inc. v. Claw, Inc., 153 Or App 190, 194 , 956 P2d 1010 (1998), we said that “since Shaffer v. Heitner, 433 US 186 , 97 S Ct 2569 , 53 L Ed 2d 683 (1977), the United States Supreme Court has made the exercise of in rem jurisdiction subject to the minimum contacts test of International Shoe Co. v. Washington, 326 US 310 , 66 S Ct 154 , 90 L Ed 95 (1945), that previously applied solely to in personam jurisdiction.” That statement should not be misunderstood. | 1 | 1999–1999 |
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.