minimum contacts inquiry in New Jersey

2025McIntyre Mach., Ltd. v. Nicastro, 564 U.S. 873, 883 (2011). 20 Accordingly, “the minimum contacts inquiry must focus on ‘the relationship among the defendant, the forum, and the litigation.’” Lebel, 115 N.J. at 323 (quoting Shaffer v. Heitner, 433 U.S. 186, 204 (1977)).

2025McIntyre Mach., Ltd. v. Nicastro, 564 U.S. 873, 883 (2011). 20 Accordingly, “the minimum contacts inquiry must focus on ‘the relationship among the defendant, the forum, and the litigation.’” Lebel, 115 N.J. at 323 (quoting Shaffer v. Heitner, 433 U.S. 186, 204 (1977)).

2025The minimum contacts requirement is satisfied if "the contacts expressly resulted from the defendant's purposeful conduct and not the unilateral activities of the plaintiff." Ibid. (citing World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297-98 (1980)).

2021The minimum contacts requirement is satisfied if "the contacts resulted from the A-1893-19 16 defendant's purposeful conduct and not the unilateral activities of the plaintiff." Ibid. (citing World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297-98 (1980)).

2025Accordingly, “the minimum contacts inquiry must focus on ‘the relationship among the defendant, the forum, and the litigation.’” Lebel v. Everglades Marina, Inc., 115 N.J. 317, 323 (1989). (pp. 15-21) 2.

2025McIntyre Mach., Ltd. v. Nicastro, 564 U.S. 873, 883 (2011). 20 Accordingly, “the minimum contacts inquiry must focus on ‘the relationship among the defendant, the forum, and the litigation.’” Lebel, 115 N.J. at 323 (quoting Shaffer v. Heitner, 433 U.S. 186, 204 (1977)).

2021Co., 339 U.S. 306, 313 (1950). 7 Mullane did not apply the minimum contacts test, but Hanson did, 357 U.S. at 251 .

2020Courts must also consider whether a nonresident defendant "purposefully avail[ed] [him]self of the privilege of conducting activities within the forum State," Hanson v. Denckla, 357 U.S. 235, 253 (1958), or "purposefully directed" his conduct into the forum State.

2010Although this Court referred to the stream of commerce theory that had developed in the federal courts as “an independent basis to satisfy the minimum-contacts standard,” id. at 476 , 508 A.2d 1127 (citing Burger King Corp. v. Rudzewicz, 471 U.S. 462, 473 , 105 S.Ct. 2174, 2182 , 85 L.Ed.2d 528, 541 (1985)), its quotations from the United States Supreme Court’s opinion in Burger King make plain that this Court recognized that stream of commerce necessarily includes the element of expectation of purchase in this state.

2010Although this Court referred to the stream of commerce theory that had developed in the federal courts as “an independent basis to satisfy the minimum-contacts standard,” id. at 476 , 508 A.2d 1127 (citing Burger King Corp. v. Rudzewicz, 471 U.S. 462, 473 , 105 S.Ct. 2174, 2182 , 85 L.Ed.2d 528, 541 (1985)), its quotations from the United States Supreme Court’s opinion in Burger King make plain that this Court recognized that stream of commerce necessarily includes the element of expectation of purchase in this state.

2010Although this Court referred to the stream of commerce theory that had developed in the federal courts as “an independent basis to satisfy the minimum-contacts standard,” id. at 476 , 508 A.2d 1127 (citing Burger King Corp. v. Rudzewicz, 471 U.S. 462, 473 , 105 S.Ct. 2174, 2182 , 85 L.Ed.2d 528, 541 (1985)), its quotations from the United States Supreme Court’s opinion in Burger King make plain that this Court recognized that stream of commerce necessarily includes the element of expectation of purchase in this state.

2010Although this Court referred to the stream of commerce theory that had developed in the federal courts as “an independent basis to satisfy the minimum-contacts standard,” id. at 476 , 508 A.2d 1127 (citing Burger King Corp. v. Rudzewicz, 471 U.S. 462, 473 , 105 S.Ct. 2174, 2182 , 85 L.Ed.2d 528, 541 (1985)), its quotations from the United States Supreme Court’s opinion in Burger King make plain that this Court recognized that stream of commerce necessarily includes the element of expectation of purchase in this state.

2021The minimum contacts requirement is satisfied as long as the "contacts result[] from the defendant's purposeful conduct and not the unilateral activities of the plaintiff." Ibid. "[W]hen the defendant is not present in the forum state, 'it is essential that there be some act by which the defendant purposefully avails [itself] of the privilege of conducting activities within [New Jersey], thus invoking the benefit and protection of its laws,'" Baanyan Software Servs., Inc. v. Kuncha, 433 N.J.

2021The minimum contacts requirement is satisfied as long as the "contacts result[] from the defendant's purposeful conduct and not the unilateral activities of the plaintiff." Ibid. "[W]hen the defendant is not present in the forum state, 'it is essential that there be some act by which the defendant purposefully avails [itself] of the privilege of conducting activities within [New Jersey], thus invoking the benefit and protection of its laws,'" Baanyan Software Servs., Inc. v. Kuncha, 433 N.J.

2010Instead, we turned to the traditional International Shoe standard, finding that the defendant’s actions met the minimum-contacts requirement and that the exercise of jurisdiction by New Jersey would not offend “ ‘traditional notions of fair play and substantial justice.’ ” Id. at 321-29 , 558 A.2d 1252 (quoting Int'l Shoe Co., supra, 326 U.S. at 316 , 66 S.Ct. at 158 , 90 L.Ed. at 102 ).

2010Instead, we turned to the traditional International Shoe standard, finding that the defendant’s actions met the minimum-contacts requirement and that the exercise of jurisdiction by New Jersey would not offend “ ‘traditional notions of fair play and substantial justice.’ ” Id. at 321-29 , 558 A.2d 1252 (quoting Int'l Shoe Co., supra, 326 U.S. at 316 , 66 S.Ct. at 158 , 90 L.Ed. at 102 ).

1994Suffice it to stay with the basics: [D]ue process requires only that in order to subject a defendant to a judgment in personam, if [the defendant] be not present within the territory of the forum, [the defendant] have certain minimum contacts with it such that the maintenance of the suit does not offend "traditional notions of fair play and substantial justice." [ International Shoe Co. v. Washington, 326 U.S. 310, 316 , 66 S.Ct. 154, 158 , 90 L.Ed. 95, 102 (1945) (quoting Milliken v. Meyer, 311 U.S. 457, 463 , 61 S.Ct. 339, 342 , 85 L.Ed. 278, 283 (1940)).] In the context of specific jurisdic

1994Suffice it to stay with the basics: [D]ue process requires only that in order to subject a defendant to a judgment in personam, if [the defendant] be not present within the territory of the forum, [the defendant] have certain minimum contacts with it such that the maintenance of the suit does not offend "traditional notions of fair play and substantial justice." [ International Shoe Co. v. Washington, 326 U.S. 310, 316 , 66 S.Ct. 154, 158 , 90 L.Ed. 95, 102 (1945) (quoting Milliken v. Meyer, 311 U.S. 457, 463 , 61 S.Ct. 339, 342 , 85 L.Ed. 278, 283 (1940)).] In the context of specific jurisdic

2013The Supreme Court determined that the state court’s “application of the minimum-contacts test in this case represents an unwarranted extension of International Shoe [ 11 ] and would, if sustained, sanction a result that is neither fair, just, nor reasonable.” Id. at 92 , 98 S.Ct. at 1697 , 56 L.Ed.2d at 141 .

2013The Supreme Court determined that the state court’s “application of the minimum-contacts test in this case represents an unwarranted extension of International Shoe [ 11 ] and would, if sustained, sanction a result that is neither fair, just, nor reasonable.” Id. at 92 , 98 S.Ct. at 1697 , 56 L.Ed.2d at 141 .

2025McIntyre Mach., Ltd. v. Nicastro, 564 U.S. 873, 883 (2011). 20 Accordingly, “the minimum contacts inquiry must focus on ‘the relationship among the defendant, the forum, and the litigation.’” Lebel, 115 N.J. at 323 (quoting Shaffer v. Heitner, 433 U.S. 186, 204 (1977)).

2025McIntyre Mach., Ltd. v. Nicastro, 564 U.S. 873, 883 (2011). 20 Accordingly, “the minimum contacts inquiry must focus on ‘the relationship among the defendant, the forum, and the litigation.’” Lebel, 115 N.J. at 323 (quoting Shaffer v. Heitner, 433 U.S. 186, 204 (1977)).

2025Daimler AG v. Bauman, 571 U.S. 117, 132-34 (2014).

2025Daimler AG v. Bauman, 571 U.S. 117, 132-34 (2014).

2020"In determining whether the defendant's contacts are purposeful, a court must examine the defendant's 'conduct and connection' with the forum state and determine whether the defendant should 'reasonably anticipate being haled into court [in the forum state].'" Bayway Refining Co., 333 N.J.

2019"In determining whether the A-1373-18T2 10 defendant's contacts are purposeful, a court must examine the defendant's 'conduct and connection' with the forum state and determine whether the defendant should 'reasonably anticipate being haled into court [in the forum state].'" Bayway Refining Co., 333 N.J.

2000In the context of specific jurisdiction, the minimum contacts inquiry must focus on “the relationship among the defendant, the forum, and the litigation.” Shaffer v. Heitner, 433 U.S. 186, 204 , 97 S.Ct 2569, 2579 , 53 L.Ed.2d 683, 698 (1977) (mere presence in the forum state of defendant’s property that is unrelated to the cause of action is insufficient to establish personal jurisdiction), quoted in Keeton v. Hustler Magazine, Inc., 465 U.S. 770, 775 , 104 S.Ct. 1473, 1478 , 79 L.Ed.2d 790, 798 (1984) (defendant’s regular circulation of magazine in forum state is sufficient to establish pers

2000In the context of specific jurisdiction, the minimum contacts inquiry must focus on “the relationship among the defendant, the forum, and the litigation.” Shaffer v. Heitner, 433 U.S. 186, 204 , 97 S.Ct 2569, 2579 , 53 L.Ed.2d 683, 698 (1977) (mere presence in the forum state of defendant’s property that is unrelated to the cause of action is insufficient to establish personal jurisdiction), quoted in Keeton v. Hustler Magazine, Inc., 465 U.S. 770, 775 , 104 S.Ct. 1473, 1478 , 79 L.Ed.2d 790, 798 (1984) (defendant’s regular circulation of magazine in forum state is sufficient to establish pers

2000In the context of specific jurisdiction, the minimum contacts inquiry must focus on “the relationship among the defendant, the forum, and the litigation.” Shaffer v. Heitner, 433 U.S. 186, 204 , 97 S.Ct 2569, 2579 , 53 L.Ed.2d 683, 698 (1977) (mere presence in the forum state of defendant’s property that is unrelated to the cause of action is insufficient to establish personal jurisdiction), quoted in Keeton v. Hustler Magazine, Inc., 465 U.S. 770, 775 , 104 S.Ct. 1473, 1478 , 79 L.Ed.2d 790, 798 (1984) (defendant’s regular circulation of magazine in forum state is sufficient to establish pers

2000In the context of specific jurisdiction, the minimum contacts inquiry must focus on “the relationship among the defendant, the forum, and the litigation.” Shaffer v. Heitner, 433 U.S. 186, 204 , 97 S.Ct 2569, 2579 , 53 L.Ed.2d 683, 698 (1977) (mere presence in the forum state of defendant’s property that is unrelated to the cause of action is insufficient to establish personal jurisdiction), quoted in Keeton v. Hustler Magazine, Inc., 465 U.S. 770, 775 , 104 S.Ct. 1473, 1478 , 79 L.Ed.2d 790, 798 (1984) (defendant’s regular circulation of magazine in forum state is sufficient to establish pers

2021Co., 339 U.S. 306, 313 (1950). 7 Mullane did not apply the minimum contacts test, but Hanson did, 357 U.S. at 251 .

2017See Waste Mgmt., supra, 138 N.J. at 121 ; see also Kulko v. Superior Ct. of Cal., 436 U.S. 84, 93-94 , 98 S. Ct. 1690, 1698 , 56 L.

2003App. 951 , 563 S.E. 2d 202, 205 (2002); In re Adoption of Copeland, 43 S.W.3d 483 , 487 (Tenn.Ct.App.2000); In Interest of M.S.B., 611 S.W. 2d 704, 706 (Tex.App.1980); State ex rel.W.A., 63 P. 3d 100 (Utah 2002).

2003Other state courts remain divided on this issue, some applying a conventional minimum-contacts analysis, see In Interest of M.A.C., 244 Ga. 645 , 261 S.E. 2d 590 , 596 (1979); In Interest of Doe, 83 Hawai'i 367 , 926 P. 2d 1290, 1296 (Haw. 1996); Matter of Laurie R., 107 N.M. 529 , *836 760 P. 2d 1295, 1297 (Ct.App.1988); In re Trueman, 99 N.C.App. 579 , 393 S.E. 2d 569, 570 (1990); and others applying the status exception, see Matter of Interest of M.L.K., 13 Kan.App. 2d 251 , 768 P. 2d 316 , 319 (1989); In re Williams, 149 N.C.

2003App. 951 , 563 S.E. 2d 202, 205 (2002); In re Adoption of Copeland, 43 S.W.3d 483 , 487 (Tenn.Ct.App.2000); In Interest of M.S.B., 611 S.W. 2d 704, 706 (Tex.App.1980); State ex rel.W.A., 63 P. 3d 100 (Utah 2002).