Vaughn v. Vaughn

“As has long been settled, and as we reaffirm today, a state court may exercise personal jurisdiction over a nonresident defendant only so long as there exist ‘minimum contacts’ between the defendant and the forum State.” World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 291 (1980) (quoting International Shoe Co. v. Washington, 326 U.S. 310, 316 (1945)).

Daughter sought support from Father under ORS 109.010. The lower court dismissed Daughter’s petition for lacking personal jurisdiction; to which Daughter assigned error. On appeal, Daughter argued that jurisdiction was permitted under several provisions of the “Uniform Interstate Family Support Act” as adopted by Oregon. See ORS 110.518(1). Father argued that Oregon could not exercise personal jurisdiction because he does not live in Oregon and has not for more than one year. “As has long been settled, . . . a state court may exercise personal jurisdiction over a nonresident defendant only so long as there exist ‘minimum contacts’ between the defendant and the forum State.” World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 291 (1980) (quoting International Shoe Co. v. Washington, 326 U.S. 310, 316 (1945)). As a general rule, Oregon courts have jurisdiction “in any action where prosecution of the action against a defendant in this state is not inconsistent with the Constitution of this state or the Constitution of the United States.” ORCP 4 L. Oregon courts have personal jurisdiction over defendants if the “but-for cause of the litigation” is an action that the defendant directed in Oregon. Robinson v. Harley-Davidson Motor Co., 354 Or 572, 594 (2013). The Court found that Oregon courts have personal jurisdiction here because the present litigation arose from Father’s family activities within Oregon. Therefore, the lower court erred when it concluded that it lacked personal jurisdiction because minimum contacts required by due process were satisfied. Reversed and remanded.