Kulko v. California Superior Court

In Kulko v. California Superior Court, 436 U.S. 84, 98 S.Ct. 1690, 56 L.Ed.2d 132 (1978), the Court held that without minimal contacts, a state cannot exercise jurisdiction over a parent residing in another state, but also indicating that if there are such minimal contacts, there is no impediment to the exercise of long-arm jurisdiction. It is fundamental "that a valid judgment imposing a personal obligation or duty in favor of the plaintiff may be entered only by a court having jurisdiction over the person of the defendant." Kulko v. California Superior Court, 436 U.S. 84, 91, 98 S. Ct. 1690, 1696, 56 L. Ed. 2d 132, 140 (1978). In addition to the presence of reasonable notice to the defendant of an action, the existence of personal jurisdiction turns on "a sufficient connection between the defendant and the forum State to make it fair to require defense of the action in the forum." Ibid., 436 U.S. at 91, 98 S. Ct. at 1696, 56 L. Ed. 2d at 141; Moreover, the "minimum contacts" test "is not susceptible of mechanical application; rather, the facts of each case must be weighed to determine whether the requisite 'affiliating circumstances' are present." Kulko, supra, 436 U.S. at 92, 98 S. Ct. at 1697, 56 L. Ed. 2d at 141.