Law School Case Brief
Vons Cos., Inc. v. Seabest Foods, Inc. - 14 Cal. 4th 434, 58 Cal. Rptr. 2d 899, 926 P.2d 1085 (1996)
A reviewing court generally does not take judicial notice of evidence not presented to the trial court. Rather, normally when reviewing the correctness of a trial court's judgment, an appellate court will consider only matters which were part of the record at the time the judgment was entered.
Appellant meat supplier was named as a defendant in a lawsuit filed in California, which claimed that it had supplied contaminated food to fast food franchises, and as a result, customers of these franchises in Washington state were injured. Appellant filed a cross-complaint against respondent franchisees, alleging that their failure to properly cook the meat caused the injuries plaintiff complained of. Respondent, which was based in Washington state, filed a motion to quash the service of process upon it, claiming that the California court lacked personal jurisdiction over it. This motion was granted by the trial court, and affirmed by the appellate court.
Were there sufficient contacts to justify the exercise of specific jurisdiction over cross-defendants?
In reversing the judgment, the court found that respondent had sufficient minimum contacts with California to satisfy the first prong of the three-prong jurisdiction test. Though the contacts were not with appellant, the court found a substantial connection between them and the instant litigation, which satisfied the second prong of the jurisdiction test. Respondent did not provide a compelling case that the exercise of jurisdiction against them would be unreasonable, and thus the third prong of the test was satisfied.
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