The test on whether Minnesota has jurisdiction over an out-of-state resident was recently addressed in Patterson Dental Supply v. Vlamis. Jurisdiction refers to the authority of a court to require someone appear before that court. As a matter of constitutionality, not every person in the United States can be made to appear in Minnesota for court.
Here are the most salient facts of Patterson Dental Supply v. Vlamis:
- Patterson Dental Supply is a Minnesota-domiciled company that conducts business on the east coast, including Pennsylvania
- Vlamis worked for Patterson Dental Supply, with his territories being Pennsylvania, New Jersey, and New York
- Vlamis never lived in Minnesota and never had a bank account in Minnesota
- Vlamis never owned property in Minnesota
- Since 1999 Vlamis came to Minnesota a total of 14 times, with the longest stretch being 4 weeks in 1999
The question the Court of Appeals (and District Court) had to answer was whether Vlamis had sufficient contact with Minnesota such that jurisdiction in Minnesota "does not offend traditional notions of fair play and substantial justice." This is a wonderfully elegant statement, but difficult to forecast its application with much certainty.
The Court of Appeals upheld the District Court's determination that Vlamis is subject to jurisdiction in Minnesota. One line from the opinion I found interesting is "Pennsylvania is not so far away that requiring Vlamis to travel to Minnesota makes jurisdiction unreasonable." Really? Pennsylvania to Minnesota is not a day trip by any means!
A key point from this opinion is you just do not know for sure how a court will decide. Here, the facts seemed quite favorable to Vlamis, but he lost. For Minnesota employers seeking to enforce employment restrictions with its employees, this is a great case to support bringing suit in Minnesota even if the employee never lived here and rarely even visited here.
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