Specific Personal Jurisdiction


Ex parte LED Corporations, Inc., [Ms. 1180629, Feb. 28, 2020] __ So. 3d __ (Ala. 2020). In a plurality opinion, the Court (Stewart, J.; Parker, C.J., and Wise and Mitchell, JJ., concur; Bolin, Shaw, Bryan, Sellers, and Mendheim, JJ., concur in the result) denies a petition for writ of mandamus filed by a Florida lighting fixture supply company and its sole owner Anthony Florence, challenging the Etowah Circuit Court’s exercise of personal jurisdiction in an action alleging breach of contract, fraud, and conversion.

The plurality opinion concludes that

[T]he contract between SDM and LED alone is not sufficient to establish LED’s and Florence’s minimum contacts with Alabama. But because the contract involved the purchase of materials that were to be shipped to an Alabama corporation for use in a construction project in Alabama and because LED, through its employee’s visit, undertook substantial efforts within Alabama to assist the school board, the owners, the architect, the general contractors, and SDM with formulating the specifications for the lighting portion of the project, SDM has established a clear nexus between LED’s conduct and the alleged injurious consequences of that conduct in Alabama such that LED should have reasonably anticipated being sued in an Alabama court.

Ms. *18-19, quoting World-Wide Volkswagen, 444 U.S. 286, 297, 100 S.Ct. 559, 567 (1980).

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