Shook Partner Jennise Stubbs and Associate Sonila Themeli have authored "How Wide are the Arms of State Court Jurisdiction?" for The Houston Lawyer. The article explores several personal jurisdiction cases, culminating with U.S. Supreme Court's decision in Bristol-Myers Squibb Co. v. Superior Court of California, San Francisco Cty.
"It is well-settled precedent that a non-resident defendant may be subject to a state court's jurisdiction only when the defendant has 'certain minimum contacts with [the forum] such that the maintenance of the suit does not offend traditional notions of fair play and substantial justice,'" Stubbs and Themeli write. "Nevertheless, lower courts have continually struggled with the perimeters of personal jurisdiction, both general and specific, resulting in conflicting decisions across the United States."
The authors then briefly trace personal jurisdiction precedents through decades of jurisprudence, then explain the ruling in Bristol-Myers Squibb. "With its holding in BMS, the Court ended any divide among the lower courts. The decision confirmed the limits of a state courts' exercise of specific jurisdiction over out-of-state defendants and continues the trend of narrowed application of personal jurisdiction."