Jurisdiction Over Out of State Defendant That Was Part of a Conspiracy
In Chromium Industries, Inc. v. Mirror Polishing & Plating Co., 448 F. Supp. 544, 552 (N.D. Ill. 1978), the plaintiff argued that the court could exercise jurisdiction over out-of-state defendants because they were part of a conspiracy and that one of their coconspirators committed an overt act causing tortious injury in Illinois. Chromium Industries, 448 F. Supp. at 552.
The court found that the defendants had not transacted business in the state and observed that if the theory were applied to subject them to personal jurisdiction in Illinois based upon the conduct of others, the result would be the forum's exercise of jurisdiction over them even though they had no individual contacts with the forum. Chromium Industries, 448 F. Supp. at 552.