PERSONAL JURISDICTION - EX PARTE DRAGOMIR
In Ex parte Dragomir, [Ms. 1091504, Dec. 17, 2010] __ So. 3d __(Ala. 2010), the Supreme Court of Alabama granted defendant's mandamus petition. The trial court denied defendant's motion to dismiss plaintiff's claims for lack of personal jurisdiction, but the Supreme Court vacated that order. This case arose from an accident between two tractor trailers near Iowa City, Iowa. The plaintiff truck driver was a resident of Alabama and the defendant truck driver, Dragonmir, was a resident of Michigan. The plaintiff filed suit in Alabama for personal injuries arising out of the accident. Dragonmir filed a motion to dismiss for lack of personal jurisdiction. It was undisputed that the trial court could not find personal jurisdiction under a specific-jurisdiction analysis since the accident took place in Iowa. However, Plaintiff asserted that Dragonmir's contacts with Alabama were continuous and systematic and that therefore the Court could find personal jurisdiction over him under a general-jurisdiction basis. The Supreme Court of Alabama disagreed and held that Dragonmir's contacts with Alabama were not sufficient to confer jurisdiction over a claim against the defendant for events occurring outside of Alabama. He had lived in Alabama until 1998, but that was "temporarily too remote," and his contact thereafter was only "sporadic."