Snyder v. Hampton Industries, Inc., 521 F. Supp. 130 (1981), involved circumstances similar to those in the case at hand. There, plaintiffs were employed by a nonresident corporation as sales representatives to sell products to customers in Maryland. Id. The corporation maintained headquarters in North Carolina. Id.
In an action filed in Maryland by the plaintiffs against the nonresident corporation, the corporation challenged Maryland's personal jurisdiction. Id.
The principle issue addressed by the Court was whether the nonresident corporation could "transact business" in Maryland, although it was not, nor had it at anytime been, physically present in Maryland. Id.
According to the Court, "if subsection (b)(1) of the Maryland long arm statute is indeed coextensive with the Due Process Clause, a nonresident can reasonably be held to have transacted business in Maryland although never physically present in the State." Id. at 141.
The foreign corporation had been for more than thirty years soliciting business in, and selling to Maryland customers. In doing so, this corporation created an ongoing presence in Maryland.
Thus, the Court concluded that the foreign corporation had had "continuous and systematic contacts" with Maryland as well as "purposeful sales to Maryland customers." Id.
In addition, the federal court agreed that "certain of the plaintiffs' acts in Maryland can be attributed to Hampton for jurisdictional purposes." Id.
The Court declined to follow the New York courts, and said:
The New York courts permit the exercise of personal jurisdiction over a nonresident who has acted in the state through an agent, when the nonresident is sued by a third party. When it is the agent suing the nonresident, those courts will not attribute the agent's in-state acts to the nonresident, even if a classic agency relationship is involved.