Although spring-break season is officially over, a recent Seventh Circuit decision offers a lesson to vacationers: When choosing your next vacation destination, make sure it’s somewhere you would be willing to visit again. You might need to litigate there.
In Noboa v. Barceló Corporación Empresarial, SA, 812 F.3d 571 (7th Cir. 2016), the Seventh Circuit reminds litigants that the proper focus of the “minimum contacts” inquiry for specific jurisdiction depends on the defendant’s intentional contacts with the forum jurisdiction. In affirming the district court’s dismissal for lack of personal jurisdiction, the Court rejected the plaintiffs’ “chain-of-causation theory,” which fundamentally relied upon the plaintiffs’ own contacts with the forum state, rather than any accident-related contacts of the defendants.