Superior Supply v. Assoc. Pipe & Supply
515 So.2d 790 (1987)
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Rule of Law:
A state court may exercise personal jurisdiction over a nonresident defendant consistent with due process when the defendant has purposefully directed business activities toward the forum state, even if the specific transaction giving rise to the litigation was negotiated remotely and the goods involved never entered the forum.
Facts:
- Superior Supply Company (Superior) is a Texas corporation with its principal place of business in Shreveport, Louisiana.
- Associated Pipe and Supply Company (Associated) is a Colorado corporation not licensed to do business in Louisiana.
- An employee of Associated visited Superior's representative in Shreveport, Louisiana, on multiple occasions in 1985 to solicit business.
- In June 1985, Superior contracted with Associated to purchase steel casing via a telephone call between its Shreveport office and Associated's representative in Colorado.
- The casing was shipped from Associated's warehouse in Texas directly to Superior's customer at a well site in Texas, never entering Louisiana.
- Approximately one month after the sale, Superior's customer notified Superior that the casing was defective.
- After investigating, Superior refunded its customer and sought to recover its losses from Associated.
Procedural Posture:
- Superior Supply Company filed a redhibition suit against Associated Pipe and Supply Company in a Louisiana trial court.
- Associated filed a declinatory exception of lack of personal jurisdiction.
- The trial court granted the exception, finding insufficient minimum contacts.
- Superior appealed to the Louisiana court of appeal (an intermediate appellate court).
- The court of appeal affirmed, holding that the plaintiff's claim did not 'arise from' the defendant's activities in the state under the pre-amendment long-arm statute, without reaching the constitutional issue.
- The Supreme Court of Louisiana granted certiorari.
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Issue:
Does a Louisiana court's exercise of personal jurisdiction over a nonresident defendant, which purposefully solicited business in Louisiana, violate the Due Process Clause of the United States Constitution when the specific transaction at issue was negotiated by telephone and involved goods that never entered Louisiana?
Opinions:
Majority - Justice Lemmon
No. The exercise of personal jurisdiction over the nonresident defendant does not violate the Due Process Clause. Louisiana's long-arm statute, as amended in 1987, is coextensive with the limits of constitutional due process, making the sole inquiry whether the defendant has sufficient minimum contacts with the state. Here, Associated purposefully directed its business activities toward Louisiana by sending its employees to solicit sales within the state. The particular sale, though negotiated by telephone, was clearly related to and likely arose from those in-state solicitation efforts. These contacts were not fortuitous or the result of another's unilateral activity. The alleged breach caused a foreseeable injury to a Louisiana resident, and Louisiana has a manifest interest in providing a forum for its residents to redress such injuries. Associated failed to present a compelling case that exercising jurisdiction would be unreasonable.
Analysis:
This decision solidifies the principle that Louisiana's long-arm statute extends personal jurisdiction to the full extent permitted by the U.S. Constitution, collapsing the former two-step statutory and constitutional analysis into a single due process inquiry. The case establishes that purposeful, in-state business solicitation can create the necessary minimum contacts for specific jurisdiction over a subsequent, related transaction, even when that transaction lacks a direct physical connection to the forum. This holding reinforces the importance of a defendant's purposeful availment of the forum state's market over the physical location of goods in a contract dispute, making it easier for resident plaintiffs to sue nonresident defendants who actively seek business within the state.
