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O'Connor v. Sandy Lane Hotel Co. - 496 F.3d 312 (3d Cir. 2007)


The Pennsylvania long-arm statute provides for jurisdiction based on the most minimum contact with the Commonwealth allowed under the Constitution of the United States. In determining whether personal jurisdiction exists, a court asks whether, under the Due Process Clause, the defendant has certain minimum contacts with the State such that the maintenance of the suit does not offend traditional notions of fair play and substantial justice. Identifying some purposeful contact with the forum is but the first step in the specific-jurisdiction analysis. The plaintiffs' claims must also "arise out of or relate to" at least one of those contacts. Unfortunately, the United States Supreme Court has not yet explained the scope of this requirement.

In the context of personal jurisdiction, although the analysis may begin with but-for causation, it cannot end there. The animating principle behind the relatedness requirement is the notion of a tacit quid pro quo that makes litigation in the forum reasonably foreseeable. Out-of-state residents who exercise the privilege of conducting activities within a state enjoy the benefits and protection of" the state's laws; in exchange, they must submit to jurisdiction over claims that arise from or relate to those activities. But-for causation cannot be the sole measure of relatedness because it is vastly overinclusive in its calculation of a defendant's reciprocal obligations. The problem is that it has no limiting principle; it literally embraces every event that hindsight can logically identify in the causative chain. If but-for causation sufficed, then defendants' jurisdictional obligations would bear no meaningful relationship to the scope of the "benefits and protection" received from the forum. As a result, the relatedness inquiry cannot stop at but-for causation.


While Plaintiffs Patrick and Marie O’Connor, a married couple, were receiving a massage treatment at the defendant Sandy Lane Hotel, the husband slipped, fell, and injured his shoulder. He and the hotel had arranged for that massage by telephone after the hotel mailed a spa brochure to his Pennsylvania home.  The United States District Court for the Eastern District of Pennsylvania dismissed their negligence claims against defendant hotel for want of personal jurisdiction. Plaintiffs appealed.


Did the District Court of Pennsylvania err in dismissing the complaint for lack of jurisdiction?




The United States Court of Appeals for the Third Circuit concluded that the hotel deliberately reached into Pennsylvania to target two of its citizens. The court reasoned that after plaintiffs' initial stay, the hotel continued to cultivate the relationship by mailing seasonal newsletters to their Pennsylvania home. Next, the hotel's Pennsylvania contacts were a but-for cause of the husband's injury. The husband's affidavit claimed that he decided to purchase spa treatments "as a result" of the hotel's solicitation. Thus, but for the mailing of the brochure, the husband never would have purchased a massage, and he would not have suffered a massage-related injury. Finally, the appellate court noted that the hotel failed to present a compelling case of unreasonableness, so jurisdiction in Pennsylvania comported with fair play and substantial justice. The court then reversed the dismissal of the complaint and remanded to the District Court for further proceedings, concluding that the district court had specific jurisdiction to adjudicate the plaintiffs’ claims.

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