South-Western Legal Studies in Business

Nevada Casino's Efforts to Attract California Patrons Gives California Courts Jurisdiction
Description Appeals courts held that California courts have personal jurisdiction over Nevada hotels and casinos sued by a California resident. The casinos direct advertising efforts at California residents and accept their business, so the state of California has a significant interest in their business dealings.
Topic Court Procedure
Key Words Personal Jurisdiction; Nonresident; Business Activities
C A S E   S U M M A R Y
Facts Snowney, a California resident, sued Harrah’s and other Nevada casino operators in a class action suit claiming unfair competition, breach of contract, and false advertising. He brought suit in California state court. The trial court dismissed the suit for lack for personal jurisdiction. Snowney appealed.
Decision

Reversed. In determining whether the exercise of jurisdiction over a nonresident would be fair and reasonable, a court must consider 1) the burden on the defendant of defending an action in the forum; 2) the forum state’s interest in adjudicating the dispute; 3) the plaintiff’s interest in obtaining relief; 4) judicial economy; and 5) the states’ shared interest in furthering fundamental substantive social policies. The hotels and casinos purposefully directed advertising at California residents; they also conducted business with some residents by an interactive web site. They solicited and received the patronage of California residents. These activities created sufficient connections for California courts to have personal jurisdiction over the hotels and casinos.

Citation Snowney v. Harrah’s Entertainment, 11 Cal.Rptr.3d 35 (Ct. App., Calif., 2004)

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