Law School Case Brief
Superior Supply Co. v. Associated Pipe & Supply Co. - 515 So. 2d 790 (La. 1987)
The obvious threshold question in determining whether the exercise of jurisdiction over a nonresident is proper is whether any contacts or relationships exist which were the foreseeable result of the nonresident's purposeful conduct. After determining the existence of contacts, the court examines the quality and nature of the contacts and determines whether it is reasonable, in the light of all relevant factors, to require the nonresident to defend himself in the forum state.
Plaintiff resident, which was a Texas corporation with its principal place of business in Louisiana, contracted to purchase steel casing for oil wells from defendant nonresident, which was a Colorado corporation and had no office in Louisiana. In 1985, plaintiff contracted to purchase steel casing for oil wells from defendant. Approximately one month after the sale, plaintiff was notified that the casing was defective. Plaintiff refunded the vendee and filed the instant redhibition suit against defendant. Asserting its nonresident status, defendant filed a declinatory exception of lack of personal jurisdiction. The trial judge ruled that the Louisiana court could not exercise personal jurisdiction over defendant, concluding that there were not sufficient minimal contacts arising out of defendant's activities within this state. On appeal, the intermediate court affirmed on the basis of statutory interpretation without reaching the constitutional due process issue. Plaintiff resident sought further review.
Whether the exercise of personal jurisdiction over defendant nonresident corporation under the long-arm statute, La. Rev. Stat. Ann. § 13:3201 et seq., violated the nonresident's constitutional due process rights.
On appeal, the Supreme Court of Louisiana reversed the judgments of the lower courts and overruled the exception of lack of personal jurisdiction. Under the express terms of the present long-arm statute (which was amended in 1987), the sole inquiry into jurisdiction over a nonresident is a one-step analysis of the constitutional due process requirements. If the assertion of jurisdiction meets the constitutional requirements of due process, the assertion of jurisdiction is authorized under the long-arm statute. The limits of Louisiana's long-arm statute and the limits of constitutional due process are now coextensive.
The Court found that defendant nonresident was in the business of selling pipe and related supplies far beyond the borders of Colorado. By sending its employees to solicit sales in Louisiana and by selling pipe to Louisiana residents, the nonresident purposefully directed its business activities toward the forum state. The Court ruled that the nonresident's contacts were clearly related to the litigation and were not fortuitous or the result of unilateral activity of a third person. Finally, defendant nonresident's alleged failure to supply material in accordance with the contract caused foreseeable injury to a Louisiana resident. Louisiana has a manifest interest in providing its residents with a convenient forum for redressing contractual breaches by nonresidents who solicit business in this state.
The Court concluded that the exercise of personal jurisdiction over the nonresident under La. Rev. Stat. Ann. § 13:3201 et seq. did not violate the nonresident's constitutional due process rights.
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