New Hampshire
How Bristol-Myers Squibb Co. v. Superior Court applies in New Hampshire: state-specific rules, key cases, and bar exam notes for Civil Procedure — Personal Jurisdiction.
New Hampshire law follows the principles established in Bristol-Myers Squibb Co. v. Superior Court, emphasizing that for a court to assert personal jurisdiction over a defendant, there must be sufficient connections between the defendant and the state where the court sits. Generally, New Hampshire applies a two-part test involving both specific and general jurisdiction based on these connections.
In New Hampshire, personal jurisdiction is established when a defendant has sufficient minimum contacts with the state such that the suit does not offend traditional notions of fair play and substantial justice, consistent with the due process requirements outlined in Bristol-Myers Squibb.
The New Hampshire Supreme Court found personal jurisdiction was not established where the defendant had minimal contacts with the state.
The court upheld personal jurisdiction based on the defendant's purposeful availment of the state's market.
Personal jurisdiction was denied when the plaintiff's claims arose from a single isolated transaction in the state.
New Hampshire's approach is similar to the federal standard under the International Shoe v. Washington precedent, focusing on the 'minimum contacts' test. However, New Hampshire courts may be more conservative in their interpretation of sufficient connections required for general jurisdiction compared to some federal courts.
Understanding the principles from Bristol-Myers Squibb is critical for the New Hampshire bar exam, particularly in questions involving personal jurisdiction and how it relates to both specific and general jurisdiction.