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Determining whether an Ohio trial court has personal jurisdiction over a nonresident defendant involves a two-step analysis: (1) whether the long-arm statute and the applicable rule of civil procedure confer jurisdiction, and if so, (2) whether the exercise of jurisdiction would deprive the nonresident defendant of the right to due process of law under the Fourteenth Amendment to the United States Constitution.
Appellee manufacturer, Kauffman Racing Equipment, L.L.C., was an Ohio limited liability company, which maintained its sole business operations and office in Ohio. Appellee constructed engine blocks and related high-performance automotive equipment for public sale. Appellant, Scott Roberts, a 30-year resident of Virginia and has never physically entered Ohio, purchased an engine block from appellee after viewing the block on appellee’s website. Eight months after purchasing the engine block, appellant contacted appellee by telephone, claiming that the block was defective. Although its products were sold "as is," appellee offered to retrieve the block from Virginia and bring it back to appellee's Ohio office for inspection. Investigation revealed that substantial modifications had been made from the block’s original specifications. Believing that the modifications were the cause of the defects, appellee declined to buy back the block and instead shipped it back to appellant in Virginia. Appellant was dissatisfied. As a result, from October 18, 2006 through November 2006, appellant posted numerous rancorous criticisms of appellee on various websites devoted to automobile racing equipment and related subjects. Consequently, appellee filed a complaint in a court of common pleas, for money damages from appellant for defamation and intentional interference with contracts and business relationships. The trial court granted appellant’s motion to dismiss for lack of personal jurisdiction. The Fifth District Court of Appeals of Ohio reversed the trial court's judgment. A discretionary appeal was accepted.
Could an Ohio court properly assert personal jurisdiction over a nonresident defendant when jurisdiction was predicated on that defendant’s publication of allegedly defamatory statements on the Internet?
The state supreme court found that the appellee manufacturer made a sufficient showing that the appellant buyer caused tortious injury in Ohio by acts committed outside of Ohio with the purpose of injuring the manufacturer. Therefore, Ohio's long-arm statute, R.C. 2307.382, and Civ. R. 4.3 conferred jurisdiction over the buyer and an exercise of jurisdiction by the trial court would not have deprived the buyer of the right to due process of law under the Fourteenth Amendment. According to the court, when defamatory statements regarding an Ohio plaintiff were made outside the state yet with the purpose of causing injury to the Ohio resident and there was a reasonable expectation that the purposefully inflicted injury will occur in Ohio, the requirements of R.C. 2307.382(A)(6) were satisfied.