Hinners v. Robey

Summary

The Supreme Court of Kentucky held that Kentucky's long-arm statute authorized jurisdiction over a Missouri vehicle seller because the transaction involved contracting to supply goods or services in Kentucky. However, the court concluded that a single eBay vehicle sale did not establish sufficient minimum contacts or purposeful availment to satisfy federal due process. The court therefore affirmed the Court of Appeals' reversal of the Kentucky trial court's default judgment.

Holdings

1. KRS 454.210(2)(a)(2) authorized personal jurisdiction because Robey contracted to supply goods and warranty services in Kentucky, and Hinners's fraud and warranty claims had a reasonable and direct nexus to that statutory predicate.
2. Federal due process did not permit Kentucky to exercise specific personal jurisdiction over Robey based solely on this single Internet sale because Robey did not purposefully avail himself of acting in or causing a consequence in Kentucky, and his connections with Kentucky were insufficiently substantial and reasonable.

Questions Presented

1. Whether Kentucky's long-arm statute, KRS 454.210, authorized personal jurisdiction over Robey based on his contract to supply the vehicle and warranty in Kentucky.
2. Whether exercising specific personal jurisdiction over Robey based on a single eBay vehicle sale comported with federal due process and minimum-contacts requirements.

Disposition

affirmed