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The Due Process Clause protects an individual's liberty interest in not being subject to the binding judgments of a forum with which he has established no meaningful contacts, ties, or relations. Where a forum seeks to assert specific jurisdiction over an out-of-state defendant who has not consented to suit there, the defendant must have "purposefully directed" his activities at residents of the forum, and the litigation must result from alleged injuries that "arise out of or relate to" those activities. This "purposeful availment" requirement ensures that a defendant will not be haled into a jurisdiction solely as a result of "random," "fortuitous," or "attenuated" contacts.
Defendant veterinarian, Dr. Steven White, performed a physical exam of the horse at the seller’s Nebraska ranch. Plaintiffs brought suit in the Superior Court of Georgia against defendant sellers and defendant veterinarian, alleging that the horse purchased was suffering from a disease. Defendants moved for dismissal, contending that personal jurisdiction was not afforded under the Georgia Long Arm Statute, O.C.G.A. § 9-10-91. Specifically, defendant veterinarian alleged that he was a resident of Nebraska, has never resided in the State of Georgia, and has never had any business contact with the State of Georgia. The trial court denied the defendant veterinarian’s motion to dismiss. Defendant veterinarian appealed.
Did the trial court of Georgia have personal jurisdiction over defendant veterinarian?
The court reversed the trial court’s judgment, holding that the denial of the motion to dismiss could not be sustained on the ground that the veterinarian was transacting business within Ga. Code. Ann. § 9-10-91(1) because the veterinarian had only a single attenuated contact with Georgia which was incidental to the completion of his professional services in Nebraska. Moreover, the court held that § 9-10-91(2) was not applicable as a basis for exercising personal jurisdiction because the veterinarian was never in Georgia at the time any alleged fraud was committed. Furthermore, § 9-10-91(3) was inapplicable as a basis for exercising personal jurisdiction because the veterinarian did not solicit business in Georgia or derive substantial revenue from services performed in Georgia.