Civil Procedure–In-Forum Injury May Constitute Forum Contact for Relatedness Prong of Specific Jurisdiction Inquiry–Astro-Med, Inc. v. Nihon Kohden America, Inc., 591 F.3d 1 (1st Cir. 2009)

To properly exercise specific jurisdiction over a nonresident defendant, due process requires that the defendant have certain minimum contacts with the forum, such that it would be fair to hale him into court there to defend against a claim related to those contacts.  The First Circuit has refined its minimum contacts analysis by requiring that a plaintiff’s claim relate to or arise out of the defendant’s contacts, that the defendant have purposely availed himself of the forum, and that the exercise of jurisdiction be reasonable.  When a defendant, although not physically present in the relevant forum, intentionally engages in tortious conduct that injures a plaintiff located there, courts will evaluate the injuries or “effects” when analyzing whether a sufficient connection exists between the plaintiff’s claim and the defendant’s contacts.  Traditionally, courts only considered in-forum effects under the purposeful availment prong of minimum contacts analysis, but in Astro-Med, Inc. v. Nihon Kohden America, Inc.,  the First Circuit strayed from its precedent by considering such effects under the relatedness prong and holding that specific jurisdiction over the defendant was proper. . .