Cornelison v. Chaney - 16 Cal. 3d 143, 127 Cal. Rptr. 352, 545 P.2d 264 (1976)

Rule:

If the defendant's activities in a forum are not so pervasive as to justify the exercise of general jurisdiction over him, then jurisdiction depends upon the quality and nature of his activity in the forum in relation to the particular cause of action. In such a situation, the cause of action must arise out of an act done or transaction consummated in the forum, or defendant must perform some other act by which he purposefully avails himself of the privilege of conducting activities in the forum, thereby invoking the benefits and protections of its laws. The crucial inquiry concerns the character of defendant's activity in the forum, whether the cause of action arises out of or has a substantial connection with that activity, and upon the balancing of the convenience of the parties and the interests of the state in assuming jurisdiction.

Facts:

In a wrongful death action by a California resident against a Nebraska resident, arising out of an accident that occurred in Nevada, the trial court granted defendant's motion to quash out-of-state service of process made on him by mail and it dismissed the action. Defendant had been engaged, for 7 years preceding the accident, in the business of hauling goods by truck in interstate commerce, making approximately 20 trips a year to this state. The accident occurred near the California border while defendant was hauling goods to a manufacturer in this state. He intended to obtain cargo in California for a return shipment to an undesignated destination. He was licensed to haul freight in California as well as in several other states and he acted as an independent contractor for several brokerage companies engaged in shipping, one of which was in California. 

Issue:

May California, consistent with the due process clause of the United States Constitution, assert jurisdiction over a nonresident individual whose essentially interstate business has a relationship to this state, but whose allegedly tortious acts occurred outside the state?

Answer:

Yes.

Conclusion:

The Supreme Court reversed, holding that, while defendant's activities in California were not so substantial or wide-ranging as to justify general jurisdiction over him to adjudicate all matters regardless of their relevance to plaintiff's cause of action, a substantial nexus was demonstrated between his California related activities and plaintiff's cause of action. After deciding that jurisdiction could be exercised, the court considered whether subjecting defendant to California jurisdiction would be fair and reasonable in the light of the inconvenience to him in defending an action in this state when balanced against the interests of plaintiff in suing locally and of the state in assuming jurisdiction. In that connection, the court pointed out that, though some of the witnesses who would testify at trial resided in Nevada, plaintiff was also a witness to the accident, that there was evidence in California on the amount of plaintiff's damages, that from the perspective of a Nebraska resident faced with litigation outside his state, there was little difference in the burden between defending in Nevada or California, and that California had an interest in providing a forum since plaintiff was a California resident. In conclusion, the court held that the interstate character of defendant's business, though not an independent basis for jurisdiction, was significant as a balancing factor.