Katz v. Katz

In Katz v. Katz, 310 N.J. Super. 25, 30-31, 707 A.2d 1353 (App.Div.1998), the Court concluded the former husband had insufficient minimum contacts with this State to establish personal jurisdiction over him in his former wife's suit seeking reimbursement of the proceeds from a custodial account, withdrawn by the husband to pay for their daughter's college education. 310 N.J. Super. at 31, 707 A.2d 1353. There, we determined the former husband did not have sufficient minimum contacts because he had not acted in a manner by which he purposefully availed himself of the privilege of conducting activities within this State, even though he had resided in New Jersey for a period seventeen years previously; the parties were married in New Jersey in 1968; he maintained a license to practice law in New Jersey, though not eligible to practice law here; and he had a small share in a limited partnership that, among all its holdings nation-wide, owned two buildings in New Jersey. Id. at 32-33, 707 A.2d 1353. The Court concluded that "whatever ties he may have had with this State have evaporated over the years and New Jersey's power to exercise personal jurisdiction over him has similarly disappeared." Id. at 32, 707 A.2d 1353. The Appellate Division pointed out that our New Jersey Supreme Court has construed that language to mean that, "We will allow out-of-state service to the uttermost limits permitted by the United States Constitution." In Katz the Appellate Division concluded that, although the defendant had at one time lived in New Jersey and married the plaintiff in New Jersey, he had been absent from the state for seventeen years, which caused whatever ties he had to evaporate and the power of the state of New Jersey to exercise personal jurisdiction over him to similarly disappear. Id.