Here’s a chart based partially on my own materials, partially on materials from Richard D. Freer, Introduction to Civil Procedure 72 (Aspen Pub. 2006), and partially from the Coleman casebook. This chart requires you to look at 1) the nature & quality of the contacts; and 2) the relation of the claim to the contacts.
A caveat about the chart: this is not the entire minimum contacts analysis, but rather a way to conceptualize the International Shoe case. Later cases expand on the steps of the analysis, and significantly modify the framework below.
Assignment: re-read International Shoe starting with “‘Presence’ in the state”. This language discusses four scenarios that correspond to the four scenarios in the table below. Label the relevant language on page 55 of the Friedenthal casebook with A, B, C, and D. Then fill in the chart below, indicating which box corresponds to A, B, C, and D.
| Contacts systematic and continuous | Contacts single, isolated, occasional, or casual | |
|
General jurisdiction Claim unrelated to contacts See Goodyear and Daimler |
BOX ___
MAYBE: General Jurisdiction might or might not exist. |
BOX ___
EASY: General Jurisdiction does not exist. |
|
Specific jurisdiction Claim arises out of or relates to contacts See Int’l Shoe and progeny up to Bristol-Myers Squibb |
BOX ___
EASY: Specific Jurisdiction likely does exist. |
BOX ___
MAYBE: Specific Jurisdiction might or might not exist. |
For another view, here’s my take on a chart from Glannon. See Joseph W. Glannon, Civil Procedure: Examples & Explanations 7 (Aspen Pub. 2006). Compare this chart with the table above to see how they say the same thing in different ways.
| D has no contacts with forum state | Single, isolated, occasional, or casual contacts | Continuous & systematic contacts | ||
| —-> | —-> | —-> | —-> | —-> |
| No PJ at all | Specific jurisdiction maybe | Specific jurisdiction likely | ||
| Not enough for general jurisdiction | General jurisdiction maybe |
Revised Aug 22, 2022 (update page number for Friedenthal casebook)