General Personal Jurisdiction

Ex parte Bradshaw, [Ms. 1190765, Dec. 4, 2020], ___ So. 3d ___ (Ala. 2020). The Court (Shaw, J.; Parker, C.J., and Bolin, Wise, Bryan, Sellers, Mendheim, Stewart, and Mitchell, JJ., concur) issues a writ of mandamus directing the Mobile Circuit Court to dismiss an action against Bradshaw for lack of personal jurisdiction. Bradshaw, a Florida resident, was involved in an automobile accident in Mississippi with Gregory, an Alabama resident.

In considering personal jurisdiction, the Court notes “because Gregory appears to have argued in the trial court that Alabama courts possess only general personal jurisdiction over Bradshaw based on his contacts with our State, we also limit our consideration to that claim. Ms. *13. In concluding Gregory did not establish general jurisdiction, the Court notes

Bradshaw’s … affidavit and deposition testimony establish[] that he has not lived in Alabama since 2006 and that his contacts with Alabama since that time have been ‘sporadic and insubstantial’ in nature, including occasional familial or other brief visits amounting to an estimated total of six contacts per year. Bradshaw’s testimony, as described above, further indicated that the nature of his contacts was largely derived from a motive of personal benefit to himself rather than an attempt to benefit from the protections of the laws of Alabama or an effort to further conduct aimed at Alabama or its citizens. Further, Bradshaw’s alleged tortious conduct, which occurred on the return trip to Florida from a family vacation to visit relatives in Mississippi, indisputably did not arise out of any action by Bradshaw that was directed at Alabama or its residents.

Ms. *14.

The Court concludes “because Gregory, even with the benefit of jurisdictional discovery, does not demonstrate minimum contacts between Bradshaw and Alabama sufficient to establish general jurisdiction, we conclude that an exercise of personal jurisdiction over Bradshaw in this case would not satisfy ‘the fair and reasonable test.’” Ms. *18, citing View-All, Inc. v. United Parcel Serv., 435 So. 2d 1198, 1201 (Ala.1983).

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