Arizona Specific Jurisdiction Over Non-Residents

Arizona courts may exercise specific jurisdiction over nonresident defendants "to the maximum extent allowed by the federal constitution." A. Uberti and C. v. Leonardo, 181 Ariz. 565, 567, 569, 892 P.2d 1354, 1356, 1358 (1995); see Ariz. R. Civ. P. 4.2(a). To comply with federal due process standards, the nonresident defendant must have sufficient minimum contacts with the forum state, and the assertion of jurisdiction must be reasonable. Uberti, 181 Ariz. at 569, 892 P.2d at 1358. A finding of minimum contacts "'must come about by an action of the defendant purposefully directed toward the forum State.'" Uberti, 181 Ariz. at 570, 892 P.2d at 1359, quoting Asahi Metal Indus. Co. v. Superior Court, 480 U.S. 102, 112, 107 S. Ct. 1026, 1032, 94 L. Ed. 2d 92, 104 (1987). See also Burger King, 471 U.S. at 474-75, 105 S. Ct. at 2183, 85 L. Ed. 2d at 542; Hoskinson v. State of California, 168 Ariz. 250, 253, 812 P.2d 1068, 1071 (App. 1990) ("The defendant must also have purposefully directed his conduct or activities at the forum state."). This "ensures that a defendant will not be haled into a jurisdiction solely as a result of 'random, ' 'fortuitous,' or 'attenuated' contacts" with the forum state. Burger King, 471 U.S. at 475, 105 S. Ct. at 2183, 85 L. Ed. 2d at 542. United States Supreme Court precedent also requires a plaintiff's claim to arise out of or relate to the defendant's forum activities before the forum state may exercise specific jurisdiction over the defendant. See, e.g., Burger King, 471 U.S. at 472, 105 S. Ct. at 2182, 85 L. Ed. 2d at 541; Helicopteros, 466 U.S. at 414, 104 S. Ct. at 1872, 80 L. Ed. 2d at 411. See also Panavision Int'l, L.P. v. Toeppen, 141 F.3d 1316, 1320 (9th Cir. 1998); Armstrong v. Aramco Serv. Co., 155 Ariz. 345, 349, 746 P.2d 917, 921 (App. 1987). If the nonresident defendant's forum-related activities "are not sufficiently connected for the court to conclude that the plaintiff's claim arises out of" those activities, dismissal is warranted. Westphal v. Mace, 671 F. Supp. 665, 668 (D. Ariz. 1987).