Washington
How Burger King Corp. v. Rudzewicz applies in Washington: state-specific rules, key cases, and bar exam notes for Civil Procedure - Personal Jurisdiction.
Washington follows the two-part test for personal jurisdiction based on the requirements of the Washington long-arm statute and federal due process. The state courts examine whether the defendant has established sufficient minimum contacts with Washington and if exercising jurisdiction complies with traditional notions of fair play and substantial justice.
Under Washington law, the personal jurisdiction can be established if the defendant engaged in purposeful availment of the state’s benefits, and the claims arise out of those activities, along with a fair play evaluation.
The court held that a defendant's online transactions with residents of Washington constituted sufficient minimum contacts to establish personal jurisdiction.
This case clarified that a defendant's contact via communications and transactions directed to individuals in Washington could justify jurisdiction under state law.
The court recognized that even sporadic contacts with the state can lead to jurisdiction if they were purposefully directed towards the forum state.
Washington’s approach closely follows federal standards set forth in International Shoe Co. v. Washington, emphasizing minimum contacts and fair play. However, Washington state courts may demonstrate a greater willingness to establish jurisdiction based on lower thresholds of contacts compared to some federal courts.
Candidates should be familiar with Washington’s long-arm statute and its interpretation, as personal jurisdiction issues arise frequently in the bar exam.