Michigan
How Calder v. Jones applies in Michigan: state-specific rules, key cases, and bar exam notes for Other.
In Michigan, courts adhere to the 'effects test' established in Calder v. Jones to evaluate personal jurisdiction based on a defendant's intentional acts that are aimed at the state. Michigan courts focus on the substantial connection between the defendant and the forum state, which allows for jurisdiction over non-resident defendants who knowingly and intentionally cause harm within the state.
In Michigan, personal jurisdiction is established through a defendant's purposeful availment of the privileges and protections of Michigan law, whereby they can reasonably foresee being haled into court in Michigan as a result of their actions.
The Michigan Court of Appeals held that a defendant's targeted advertising in Michigan constituted sufficient minimum contacts to establish personal jurisdiction.
The court ruled that a single, purposeful action directed at Michigan can support jurisdiction if it is substantial enough in relation to the cause of action.
The court found that personal jurisdiction was proper when the defendant deliberately engaged in conduct that was likely to have effects in Michigan.
Michigan's approach mirrors the federal standard established by Calder v. Jones in that it emphasizes the defendant's intentional actions and their effects within the forum state. However, Michigan courts may extend the interpretation of 'purposeful availment' more broadly in certain contexts than some federal courts.
Knowledge of Calder v. Jones and its principles on personal jurisdiction is essential for the Michigan bar exam, especially in questions concerning tort claims and jurisdiction issues.