Personal Jurisdiction - Ex Parte No. 1 Steel Products, Inc.
In Ex parte No. 1 Steel Products, Inc., [Ms. 1091781, Jul. 29, 2011] __ So. 3d __(Ala. 2011), the Supreme Court granted Defendant's petition for a writ of mandamus directing a circuit court to dismiss an action because the circuit court lacked personal jurisdiction over the defendant. The plaintiff, Garrison Steel Fabricators, entered into a contract with Defendant, No. 1 Steel Products, Inc., relating to steel fabrication work for a construction project in Massachusetts. The companies communicated via telephone, fax and e-mail during the negotiation and fabrication process, but no representative from No. 1 Steel ever visited Garrison's fabrication facility in Alabama. When the fabrication process was complete, the finished product was sent to Massachusetts. A dispute arose regarding payment due to Garrison Steel. Garrison Steel filed suit against No. 1 Steel in an Alabama circuit court. No. 1 Steel filed a motion to dismiss for lack of personal jurisdiction. The circuit court denied the motion and No. 1 Steel filed a petition for a writ of mandamus. The Supreme Court held that, despite the contact and performing pursuant to a written contract, No. 1 Steel's contacts with the State of Alabama were not sufficient for it to reasonably anticipate being hailed into court here.