personal jurisdiction analysis (Ohio) · Go Syfert
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personal jurisdiction analysis in Ohio

11 Ohio opinions name it 3 courts 1999–2015 0 in the last five years

The cases below were cited by Ohio 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 (8)

CaseFollowedCited
U.S. Sprint Communications Co. Ltd. Partnership v. Mr. K's Foods, Inc.green
ohio · 1994 · cited in 2 Ohio opinions naming this issue, 1999–2006
2 sentences

2006See, also, U.S. Sprint Communications Co., L.P. v. Mr. K's Foods, Inc. (1994), 68 Ohio St.3d 181 . {¶ 8} As to the first prong of the personal jurisdiction test, R.C. 2307.382 provides in pertinent part, "(A) A court may exercise personal jurisdiction over a person who acts directly or by an agent, as to a cause of action arising from the person's: * * * (8) Having an interest in, using, or possessing real property in this state * * *." Additionally, the relevant parts of Civ.R. 4.3, which are substantially similar to R.C. 2307.382 , provide as follows: "(A) When service permitted — service of

1999See Goldstein, 70 Ohio St.3d at 235 , 638 N.E.2d at 543-544 (the state court is "obligated” to engage in the two-part personal jurisdiction analysis), citing U.S. Sprint, 68 Ohio St.3d at 183-184 , 624 N.E.2d at 1050-1052 .

22
Maryhew v. Yovagreen
ohio · 1984 · cited in 2 Ohio opinions naming this issue, 2000–2005
2 sentences

2005See Maryhew v. Yova (1984), 11 Ohio St.3d 154 (holding certain affirmative acts by a defendant or a defendant's legal representative can constitute a waiver of a personal jurisdiction defense).

2000See Maryhew v. Yova (1984), 11 Ohio St.3d 154 , 156 ; see, generally, World-Wide Volkswagen Corp. v. Woodson (1980), 444 U.S. 286 , 100 S.Ct. 559 , 62 L.Ed.2d 490 .

22
Goldstein v. Christiansengreen
ohio · 1994 · cited in 2 Ohio opinions naming this issue, 1999–2001
2 sentences

2001See 5 SUPREME COURT OF OHIO Goldstein v. Christiansen (1994), 70 Ohio St.3d 232, 238 , 638 N.E.2d 541, 545 (“Where personal jurisdiction turns upon some fact to be determined by the trial court, its ruling that it has jurisdiction, if wrong, is simply error for which prohibition is not the proper remedy.”). {¶ 18} Under the second part of the personal jurisdiction analysis, an Ohio court may assert personal jurisdiction over a nonresident defendant if the nonresident has certain minimum contacts with Ohio so that the case does not offend traditional due process concerns of fair play and substa

2001See 5 SUPREME COURT OF OHIO Goldstein v. Christiansen (1994), 70 Ohio St.3d 232, 238 , 638 N.E.2d 541, 545 (“Where personal jurisdiction turns upon some fact to be determined by the trial court, its ruling that it has jurisdiction, if wrong, is simply error for which prohibition is not the proper remedy.”). {¶ 18} Under the second part of the personal jurisdiction analysis, an Ohio court may assert personal jurisdiction over a nonresident defendant if the nonresident has certain minimum contacts with Ohio so that the case does not offend traditional due process concerns of fair play and substa

22
World-Wide Volkswagen Corp. v. Woodsongreen
scotus · 1980 · cited in 2 Ohio opinions naming this issue, 2000–2006
2 sentences

2006The Supreme Court further narrowed its definition of `minimum contacts' in Hanson v. Denckla (1958), 357 U.S. 235 , 253 , when it held that "it is essential in each case that there be some act by which the defendant purposefully avails itself of the privilege of conducting activities with the forum state, thus invoking the benefits and protections of its laws." What is critical to the due process analysis as it relates to exercising personal jurisdiction "is that the defendant's conduct and connection with the forum state are such that he should reasonably anticipate being haled into court the

2000See Maryhew v. Yova (1984), 11 Ohio St.3d 154 , 156 ; see, generally, World-Wide Volkswagen Corp. v. Woodson (1980), 444 U.S. 286 , 100 S.Ct. 559 , 62 L.Ed.2d 490 .

12
Kentucky Oaks Mall Co. v. Mitchell's Formal Wear, Inc.green
ohio · 1990 · cited in 2 Ohio opinions naming this issue, 1999–2000
2 sentences

2000The reaching of an agreement short of a formalized contract is well within the contemplation of the definition of, "transacting business" adopted by the Ohio Supreme Court in Kentucky Oaks Mall Co. v. Mitchell's Formal Wear, supra. Having determined that Appellant transacted business in Ohio as contemplated by the long-arm statute, we must address the second prong of the personal jurisdiction test; whether exercising personal jurisdiction over Appellant violates the Due Process Clause of the Fourteenth Amendment.

1999See Kentucky Oaks, 53 Ohio St.3d at 75 , 559 N.E.2d at 479-480 .

12
Buflod v. Wilhendorf, Unpublished Decision (1-29-2007)green
ohioctapp · 2007 · cited in 1 Ohio opinions naming this issue, 2013–2013
1 sentence

2013See Buflod, 2007-Ohio-347 at ¶ 18 (noting that "though this is not a determinative factor in a court's personal jurisdiction analysis, [the choice of law provision] further suggests that appellees did not reasonably anticipate litigating in Ohio"). {¶ 14} After reviewing the record, the trial court correctly dismissed Booth's claim because it lacked jurisdiction over WWC.

11
In Re Kilburn, Unpublished Decision (3-3-2006)green
ohioctapp · 2006 · cited in 1 Ohio opinions naming this issue, 2007–2007
1 sentence

2007See In re Kilburn , Montgomery App. No. 20993, 2006-Ohio-991 (citing R.C. 3115.44 and stating "[u]nder the UIFSA, an individual has the burden of proving that the rendering State, in this case Kentucky, lacked personal jurisdiction"); Beam v. Beam Darke App. No. 02-CA-1573, 2002-Ohio-2910 (concluding that R.C. 3115.44 [A][1] allows a party to contest enforcement of an order upon a claim that the issuing court lacked personal jurisdiction over the contesting party); Emig v. Massau (2000), 140 Ohio App.3d 119 (recognizing that pursuant to R.C. 3115.44 , a party could properly raise in an Ohio co

11
State ex rel. Carpenter v. Jonesgreen
ohio · 1994 · cited in 1 Ohio opinions naming this issue, 1999–1999
2 sentences

1999See Goldstein, 70 Ohio St.3d at 235 , 638 N.E.2d at 543-544 (the state court is "obligated” to engage in the two-part personal jurisdiction analysis), citing U.S. Sprint, 68 Ohio St.3d at 183-184 , 624 N.E.2d at 1050-1052 .

1999See Goldstein, 70 Ohio St.3d at 235 , 638 N.E.2d at 543-544 (the state court is "obligated” to engage in the two-part personal jurisdiction analysis), citing U.S. Sprint, 68 Ohio St.3d at 183-184 , 624 N.E.2d at 1050-1052 .

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (10)

CaseCitedYears
Milliken v. Meyer green
scotus · 1941
2 sentences

2008Shoe Co. v. Washington (1945), 326 U.S. 310, 316 , 66 S.Ct. 154 , 90 L.Ed. 95 , quoting Milliken v. Meyer (1940), 311 U.S. 457, 463 , 61 S.Ct. 339 , 85 L.Ed. 278 .

2006See, also, U.S. Sprint Communications Co., L.P. v. Mr. K's Foods, Inc. (1994), 68 Ohio St.3d 181 . {¶ 8} As to the first prong of the personal jurisdiction test, R.C. 2307.382 provides in pertinent part, "(A) A court may exercise personal jurisdiction over a person who acts directly or by an agent, as to a cause of action arising from the person's: * * * (8) Having an interest in, using, or possessing real property in this state * * *." Additionally, the relevant parts of Civ.R. 4.3, which are substantially similar to R.C. 2307.382 , provide as follows: "(A) When service permitted — service of

22006–2008
International Shoe Co. v. Washington green
scotus · 1945
2 sentences

2008Shoe Co. v. Washington (1945), 326 U.S. 310, 316 , 66 S.Ct. 154 , 90 L.Ed. 95 , quoting Milliken v. Meyer (1940), 311 U.S. 457, 463 , 61 S.Ct. 339 , 85 L.Ed. 278 .

2006See, also, U.S. Sprint Communications Co., L.P. v. Mr. K's Foods, Inc. (1994), 68 Ohio St.3d 181 . {¶ 8} As to the first prong of the personal jurisdiction test, R.C. 2307.382 provides in pertinent part, "(A) A court may exercise personal jurisdiction over a person who acts directly or by an agent, as to a cause of action arising from the person's: * * * (8) Having an interest in, using, or possessing real property in this state * * *." Additionally, the relevant parts of Civ.R. 4.3, which are substantially similar to R.C. 2307.382 , provide as follows: "(A) When service permitted — service of

22006–2008
Prouse, Dash & Crouch, L.L.P. v. DiMarco green
ohio · 2007
1 sentence

2015First Assignment of Error {¶ 8} As a preliminary matter, we note that in her memorandum contra to Budde's motion to dismiss, Simmons employed the "two-step" specific personal jurisdiction analysis for nonresidents set by the Supreme Court of Ohio in Goldstein and more recently in Kauffman Racing at ¶ 28, and Fraley v. Estate of Oeding, 138 Ohio St.3d 250 , 2014-Ohio-452, ¶ 12 . {¶ 9} However, on appeal, Simmons continued to advance the two-step specific personal jurisdiction analysis for nonresidents but then shifted her argument to contend, for the first time, that Budde is actually a "reside

12015–2015
Fraley v. Estate of Oeding green
ohio · 2014
2 sentences

2015First Assignment of Error {¶ 8} As a preliminary matter, we note that in her memorandum contra to Budde's motion to dismiss, Simmons employed the "two-step" specific personal jurisdiction analysis for nonresidents set by the Supreme Court of Ohio in Goldstein and more recently in Kauffman Racing at ¶ 28, and Fraley v. Estate of Oeding, 138 Ohio St.3d 250 , 2014-Ohio-452, ¶ 12 . {¶ 9} However, on appeal, Simmons continued to advance the two-step specific personal jurisdiction analysis for nonresidents but then shifted her argument to contend, for the first time, that Budde is actually a "reside

2015First Assignment of Error {¶ 8} As a preliminary matter, we note that in her memorandum contra to Budde's motion to dismiss, Simmons employed the "two-step" specific personal jurisdiction analysis for nonresidents set by the Supreme Court of Ohio in Goldstein and more recently in Kauffman Racing at ¶ 28, and Fraley v. Estate of Oeding, 138 Ohio St.3d 250 , 2014-Ohio-452, ¶ 12 . {¶ 9} However, on appeal, Simmons continued to advance the two-step specific personal jurisdiction analysis for nonresidents but then shifted her argument to contend, for the first time, that Budde is actually a "reside

12015–2015
Hudgins v. Hudgins green
ohioctapp · 1992
1 sentence

2007See In re Kilburn , Montgomery App. No. 20993, 2006-Ohio-991 (citing R.C. 3115.44 and stating "[u]nder the UIFSA, an individual has the burden of proving that the rendering State, in this case Kentucky, lacked personal jurisdiction"); Beam v. Beam Darke App. No. 02-CA-1573, 2002-Ohio-2910 (concluding that R.C. 3115.44 [A][1] allows a party to contest enforcement of an order upon a claim that the issuing court lacked personal jurisdiction over the contesting party); Emig v. Massau (2000), 140 Ohio App.3d 119 (recognizing that pursuant to R.C. 3115.44 , a party could properly raise in an Ohio co

12007–2007
Emig v. Massau green
ohioctapp · 2000
1 sentence

2007See In re Kilburn , Montgomery App. No. 20993, 2006-Ohio-991 (citing R.C. 3115.44 and stating "[u]nder the UIFSA, an individual has the burden of proving that the rendering State, in this case Kentucky, lacked personal jurisdiction"); Beam v. Beam Darke App. No. 02-CA-1573, 2002-Ohio-2910 (concluding that R.C. 3115.44 [A][1] allows a party to contest enforcement of an order upon a claim that the issuing court lacked personal jurisdiction over the contesting party); Emig v. Massau (2000), 140 Ohio App.3d 119 (recognizing that pursuant to R.C. 3115.44 , a party could properly raise in an Ohio co

12007–2007
Rockey v. 84 Lumber Co. green
ohio · 1992
1 sentence

2007See In re Kilburn , Montgomery App. No. 20993, 2006-Ohio-991 (citing R.C. 3115.44 and stating "[u]nder the UIFSA, an individual has the burden of proving that the rendering State, in this case Kentucky, lacked personal jurisdiction"); Beam v. Beam Darke App. No. 02-CA-1573, 2002-Ohio-2910 (concluding that R.C. 3115.44 [A][1] allows a party to contest enforcement of an order upon a claim that the issuing court lacked personal jurisdiction over the contesting party); Emig v. Massau (2000), 140 Ohio App.3d 119 (recognizing that pursuant to R.C. 3115.44 , a party could properly raise in an Ohio co

12007–2007
Hanson v. Denckla green
scotus · 1958
1 sentence

2006The Supreme Court further narrowed its definition of `minimum contacts' in Hanson v. Denckla (1958), 357 U.S. 235 , 253 , when it held that "it is essential in each case that there be some act by which the defendant purposefully avails itself of the privilege of conducting activities with the forum state, thus invoking the benefits and protections of its laws." What is critical to the due process analysis as it relates to exercising personal jurisdiction "is that the defendant's conduct and connection with the forum state are such that he should reasonably anticipate being haled into court the

12006–2006
Jackson v. State Street Bank & Trust Co. green
ohioctapp · 1996
1 sentence

2003See also, Herbuck v. Lajolla Capital (Sept. 27, 2000), Summit App. No. 19586 (nonresident's tortious acts, including conversion, outside Ohio while knowing that stock involved was of an Ohio corporation satisfied requirements of R.C. 2307.382 (A)(6)); Jackson v. State Street Bank Trust Co. (1996), 110 Ohio App.3d 388 (out-of-state bank's failure to verify checks forged and cashed in Ohio causing Ohio resident to lose nearly all of her insurance proceeds was sufficient to establish tortious injury in Ohio). {¶ 21} Next, we consider the second part of the personal jurisdiction analysis under whi

12003–2003
Sherry v. Geissler U. Pehr Gmbh green
ohioctapp · 1995
2 sentences

1999The court notes that the personal jurisdiction analysis concludes when the plaintiff fails to satisfy the long-arm statute by establishing that the defendant did not “[transact] any business in [Ohio].” See Sherry, 100 Ohio App.3d at 74 , 651 N.E.2d at 1386-1387 .

1999The court notes that the personal jurisdiction analysis concludes when the plaintiff fails to satisfy the long-arm statute by establishing that the defendant did not “[transact] any business in [Ohio].” See Sherry, 100 Ohio App.3d at 74 , 651 N.E.2d at 1386-1387 .

11999–1999

Where else courts name it

TX 62 (1997–2026) DE 25 (1987–2026) NC 23 (1977–2025) NY 23 (1992–2026) CA 18 (1994–2025) AL 15 (2001–2025) FL 13 (1985–2024) IL 12 (1991–2026) OH 11 (1999–2015) MO 11 (1982–2024) LA 10 (1990–2019) MI 10 (1997–2021) NE 9 (1985–2024) ME 9 (2000–2022) TN 8 (1999–2025) CO 8 (1992–2026) AZ 7 (2000–2025) MN 7 (1999–2019) MD 7 (1986–2024) WI 6 (1989–2022) NM 5 (2015–2025) WA 4 (2015–2022) NJ 4 (2020–2025) VT 4 (2005–2025) MA 4 (1998–2012) PA 4 (2013–2025) OK 4 (2023–2025) VI 4 (2012–2023) SC 4 (2009–2023) GA 4 (2013–2025) MS 3 (1991–2020) MT 3 (2015–2020) OR 3 (2022–2023) AR 3 (2006–2014) CT 2 (2002–2003) DC 2 (2001–2020) UT 2 (2012–2016) AK 2 (1997–2022) IN 2 (1990–2015) IA 2 (2007–2013)

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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