In Architectural Woodcraft Co. v. Read, 464 A.2d 210 (Me. 1983), the plaintiff, a manufacturer of spiral staircases, and the defendant, a resident of California, entered into a contract for the construction of a staircase. Id. at 211.
The defendant paid a deposit by check, the plaintiff shipped the staircase to California and the defendant then paid the balance due by check. Id. When the defendant discovered the staircase had sustained damage in transit, he stopped payment on his check but retained the staircase. Id.
The plaintiff subsequently brought suit in Maine seeking damages for breach of contract and conversion. Id. The defendant never set foot in Maine or conducted any other business here. Id. at 212.
The Law Court held that the existence of a single contract with a resident plaintiff coupled with the use of interstate communications was insufficient to establish a basis for asserting jurisdiction over a defendant. Id. at 213.
In Akins, the First Circuit held that issuance of stumpage permits was an internal tribal matter in part because it concerned only lands acquired with federal funds and such activity affected the Tribes' ability to harvest natural resources from the land. (See id.)