Sender v. Powell
In Sender v. Powell (Colo.Ct.App. 1995) 902 P.2d 947, a California limited partner of a Colorado partnership was sued to recover withdrawals from the partnership in excess of his contributions under an alleged Ponzi scheme. (Id. at p. 949.)
The Colorado Court of Appeals concluded the partner's contacts with the state were insufficient to support the exercise of personal jurisdiction over him. The partner had purchased his interest in the partnership in California, all the documents were signed in California, all meetings regarding the partnership occurred in California, the partner did not travel to Colorado in connection with his investment, and he did not conduct any other business within the state. (Id. at pp. 951-952.)
The only contacts the partner had with Colorado were his receipt of payments that had originated in that state. Furthermore, the court concluded, the claim asserted by the plaintiff did not arise from any conduct of the partner in the forum state but from the conduct of the partnership itself. (Id. at p. 952.) In other words, the claims did not arise from any contacts of the limited partner in the forum state.