M.C. v. Quest Global, Inc.

For Oregon to exercise specific personal jurisdiction over a defendant, there must be “minimum contacts’’ between the defendant and Oregon. World-Wide Volkswagen Corp. v. Woodson, 444 US 286, 291-92, 100 S Ct 559, 62 L ED 2d 490 (1980).

Colpitts, an Oregonian truck driver for Quest, was told to dismiss her stalking protective order (SPO) against another Quest employee or risk losing her job. She declined to do so, and her employment was ultimately terminated. Colpitts appealed the trial court’s dismissal of their case, assigning error to the conclusion that Quest did not have minimum contacts with Oregon to support specific personal jurisdiction. Colpitts argued that Oregon has specific personal jurisdiction over Quest because Quest hired Oregonians truck drivers, conducted business in the state, and sought to avail itself of Oregon’s judicial system by telling Colpitts to dismiss an Oregon SPO to further its own business interests. Quest argued that it did not purposefully avail itself of the Oregon and that even it had, this litigation did not arise out of those activities. For Oregon to exercise specific personal jurisdiction over a defendant, there must be “minimum contacts” between the defendant and Oregon. World-Wide Volkswagen Corp. v. Woodson, 444 US 286, 291-92, 100 S Ct 559, 62 L ED 2d 490 (1980). The Court found that when Quest gave Colpitts an ultimatum to dismiss her SPO or risk losing her job, it constituted minimum contact with Oregon. This contact gave rise to reasonably foreseeable litigation. Thus, Quest was subject to specific personal jurisdiction. Reversed and remanded.