Sioux Pharm, Inc. and Sioux Biochemical, Inc. v. Summit Nutritionals International, Inc.

Summary

The Iowa Supreme Court held that Summit Nutritionals International, Inc.’s inaccurate statement on a passive website identifying an Iowa manufacturing facility did not establish general personal jurisdiction because Summit was not essentially at home in Iowa. The court nevertheless affirmed denial of Summit’s motion to dismiss because the totality of its Iowa contacts, including its supply contract, website statement, and related product sale, supported specific jurisdiction over claims arising from those contacts. The decision also discusses waiver, estoppel, and website-based jurisdiction under the Calder effects test and Zippo sliding-scale approach.

Holdings

1. A nonresident corporation's inaccurate statement on a passive website that it has a manufacturing facility in Iowa, standing alone, does not establish general personal jurisdiction in Iowa.
2. Summit's annual supply contract with an Iowa company, brief site visit, website statement, and other Iowa contacts did not establish general personal jurisdiction because Summit was not essentially at home in Iowa.
3. Summit's Iowa contacts, considered in their totality and in light of the Calder effects test, established specific personal jurisdiction over Summit in Sioux Pharm's unfair-competition action.

Questions Presented

1. Whether Summit's inaccurate statement on a passive website that it had an Iowa manufacturing facility established general personal jurisdiction in Iowa.
2. Whether the totality of Summit's Iowa contacts, including its supply contract with an Iowa company, its president's brief Iowa visit, its website statement, and its sale of a product sample in Iowa, established general personal jurisdiction.
3. Whether those contacts, considered in relation to Sioux Pharm's unfair-competition claims and under the Calder effects test, established specific personal jurisdiction consistent with due process.

Disposition

affirmed