minimum contacts factors in Indiana

2012We note that the court in JPMorgan stated that Brockman and Mart "applied Calder; " however, although these cases applied Caller’s principles in reaching their decisions, they did not examine the Calder decision itself and focused their analysis on the traditional minimum contacts factors. 882 N.E.2d at 750 ; see Mart, 703 N.E.2d at 193 ("While it is true that such contacts would not ordinarily subject a nonresident to jurisdiction in our state, the law is clear that an ordinarily insignificant contact with a state becomes constitutionally significant when it gives rise to the claim involved i

2012Thus, for our purposes, in Indiana the burden is on the defendant to show that at least one element of the express aiming test is not present. [7] As observed by the court in Bancroft & Masters, "[e]xpress aiming is a concept that in the jurisdictional context hardly defines itself." 223 F.3d at 1087 . [8] We note that the court in JPMorgan stated that Brockman and Mart "applied Calder ; " however, although these cases applied Calder's principles in reaching their decisions, they did not examine the Calder decision itself and focused their analysis on the traditional minimum contacts factors.

2017T.R.4.4(A)(1). [20] Such a mechanical approach to the minimum contacts test we have applied since International Shoe defeats the purpose of what the due process clause seeks to ensure — the “fair and orderly administration of law,” and the ability of out- Court of Appeals of Indiana | Memorandum Decision 10A01-1612-PL-2770 | September 5, 2017 Page 10 of 17 of-state defendants to “reasonably anticipate being haled into the courts of [a] state for any matter.” Davis v. Simon, 963 N.E.2d 46, 51 (Ind. Ct. App. 2012) (citing Helicopteros, 466 U.S. at 415 n. 9, 104 S. Ct. 1868 ).

2017T.R.4.4(A)(1). [20] Such a mechanical approach to the minimum contacts test we have applied since International Shoe defeats the purpose of what the due process clause seeks to ensure — the “fair and orderly administration of law,” and the ability of out- Court of Appeals of Indiana | Memorandum Decision 10A01-1612-PL-2770 | September 5, 2017 Page 10 of 17 of-state defendants to “reasonably anticipate being haled into the courts of [a] state for any matter.” Davis v. Simon, 963 N.E.2d 46, 51 (Ind. Ct. App. 2012) (citing Helicopteros, 466 U.S. at 415 n. 9, 104 S. Ct. 1868 ).

2015Id. at 970 .

2012Thus, for our purposes, in Indiana the burden is on the defendant to show that at least one element of the express aiming test is not present. [7] As observed by the court in Bancroft & Masters, "[e]xpress aiming is a concept that in the jurisdictional context hardly defines itself." 223 F.3d at 1087 . [8] We note that the court in JPMorgan stated that Brockman and Mart "applied Calder ; " however, although these cases applied Calder's principles in reaching their decisions, they did not examine the Calder decision itself and focused their analysis on the traditional minimum contacts factors.

2004Citing Matter of Paternity of Robinaugh, 616 N.E.2d 409 (Ind.Ct.App.1993), she urges that her paternity action, as a proceeding relating to custody and the adjudication of status, is an exception to the minimum contacts requirement normally associated with personal jurisdiction.

1999According to Hotmix, the Pannette decision has been superceded by the more recent decisions of Mullen v. Cogdell, 643 N.E.2d 390 (Ind.Ct.App.1994), reh’g de *829 nied, trans. denied and Yates-Cobb v. Hays, 681 N.E.2d 729 (Ind.Ct.App.1997). 2 Hotmix, in support of its position, also quotes Professor Harvey who opines that the holding in Pannette is incorrect. 3 However, contrary to Hotmix’s assertion, the Pannette decision has not been super-ceded by more recent decisions.

1999According to Hotmix, the Pannette decision has been superceded by the more recent decisions of Mullen v. Cogdell, 643 N.E.2d 390 (Ind.Ct.App.1994), reh’g de *829 nied, trans. denied and Yates-Cobb v. Hays, 681 N.E.2d 729 (Ind.Ct.App.1997). 2 Hotmix, in support of its position, also quotes Professor Harvey who opines that the holding in Pannette is incorrect. 3 However, contrary to Hotmix’s assertion, the Pannette decision has not been super-ceded by more recent decisions.

1999“To find that a consumer has submitted to personal jurisdiction in a foreign state ... based upon an order for goods strains the boundaries of the minimum contacts requirement.” Id. at 756 .

1982As explained in Shaffer v. Heitner, (1977) 433 U.S. 186 , 97 S.Ct. 2569 , 53 L.Ed.2d 683 , which extended the minimum contacts standard of International Shoe, supra, to in rem actions: “[Tjhe presence of property in a State may bear on the existence of jurisdiction by providing contacts among the forum State, the defendant, and the litigation.

1982As explained in Shaffer v. Heitner, (1977) 433 U.S. 186 , 97 S.Ct. 2569 , 53 L.Ed.2d 683 , which extended the minimum contacts standard of International Shoe, supra, to in rem actions: “[Tjhe presence of property in a State may bear on the existence of jurisdiction by providing contacts among the forum State, the defendant, and the litigation.