Reeves v. Phillips

In Reeves v. Phillips, 54 AD2d 854 (1st Dep't 1976) a Texan co-conspirator was held to be subject to jurisdiction based on actions of co-conspirators because the Texan was on the board of directors that committed the alleged tortious act in New York. Id. at 855. Although the Texan co-conspirator was not present for the specific board meeting where the tortious act was committed, "it [wa]s not disputed that a board member at the meeting in New York telephoned the defendant and spoke with him concerning the response to be made to the take-over bid. The law firm of which defendant was a partner proceeded immediately to institute proceedings to impede the take-over, which proceedings were ultimately unsuccessful." Id. In addition, the Texan co-conspirator had also traveled to New York for other board meetings. Id. In totality, the Texan co-conspirator satisfied the minimum contacts requirement and the tort had a substantial connection to New York. Id.