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In Oklahoma, What Constitutes Sufficient Minimum Contacts Such That the Lawsuit Does Not Offend Traditional Notions of Fair Play and Substantial Justice?

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In Sanchez v. White County Medical Center, No. 16-5154, (10th Cir. April 2018), the United States Court of Appeals for the Tenth Circuit determined how to answer that question.

This case arises from a car accident on August 5, 2013 in Creek County, Oklahoma. According to plaintiffs’ complaint, one vehicle was operated by Debra Standage. At the time of the accident, Standage was accompanied by her grandson, referred to by the parties as I.S. The other vehicle was operated by Eric Goodwin (“Goodwin”), who was acting in the course and scope of his employment at Total Assessment Solutions Corporation (“TASC”). Sometime after May 10, 2013, Goodwin moved from Arkansas to Oklahoma in connection with his employment at TASC. The Plaintiffs brought a negligence action against Goodwin and TASC in Oklahoma state court. Goodwin and TASC then asserted a third-party claim against White County Medical Center (“WCMC”) alleging that Goodwin was negligently prescribed a generic medication for his high blood pressure, which caused the accident. In an amended pleading, Plaintiffs asserted a direct claim against WCMC. The Oklahoma Supreme Court issued a writ limiting discovery to jurisdictional issues. Plaintiffs then dismissed their state court action without prejudice and initiated the present action in federal court. The lower court dismissed. Plaintiffs appealed.

A federal district court may exercise jurisdiction over a properly served defendant who is subject to the jurisdiction of a court of general jurisdiction where the district court is located. Oklahoma’s long-arm statute provides that an Oklahoma court may exercise jurisdiction on any basis consistent with the Constitution of this state and the Constitution of the United States. Because no party argued any state constitutional objection, the relevant inquiry on appeal is whether the United States Constitution places any limits on Oklahoma’s ability to exercise jurisdiction over WCMC. The Court looked at the federal constitutional limitations imposed on Oklahoma’s exercise of specific jurisdiction over non-resident defendants. Fundamental principles of due process require that a defendant have certain minimum contacts with the forum such that the maintenance of the suit does not offend traditional notions of fair play and substantial justice.

Jurisdiction is proper where the contacts proximately result from actions by the defendant that create a substantial connection with the forum State. The substantial connection between the defendant and the forum State necessary for a finding of minimum contacts must come about by an action of the defendant purposefully directed toward the forum State. The Court concluded that Oklahoma’s exercise of personal jurisdiction over WCMC in this action fails to comply with due process. WCMC is an Arkansas corporation that maintains a clinic in Searcy, Arkansas. Limited discovery on jurisdictional issues revealed that WCMC provides healthcare services exclusively in Arkansas, does not seek to render healthcare services in Oklahoma, does not advertise in Oklahoma, and does not have any business or ownership interests in Oklahoma. Due to a lack of personal jurisdiction, the lower court’s dismissal is affirmed.

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