Trump v. Eighth Judicial District Court, 109 Nev. 687

857 P.2d 740 (1993) · Supreme Court of Nevada · July 27, 1993 · No. No. 23912

Summary

The Supreme Court of Nevada considered whether Nevada could exercise personal jurisdiction over Donald J. Trump in an action alleging intentional interference with contractual relations. The court held that the plaintiff made a prima facie showing that Trump's contacts with Nevada, including contacts attributable through his alleged personal agent, satisfied due process requirements for specific personal jurisdiction. The court denied Trump's petition for a writ of prohibition seeking to quash service of process.

Holdings

  1. A writ of prohibition is an appropriate remedy for a district court's erroneous refusal to quash service of process for lack of personal jurisdiction.
  2. When a personal-jurisdiction challenge is decided on a pretrial, non-evidentiary motion, the plaintiff must present competent evidence establishing a prima facie case of jurisdiction; the burden does not shift to the defendant, and factual disputes are resolved in the plaintiff's favor.
  3. For purposes of the pretrial prima facie jurisdiction determination, GNLV sufficiently showed that Ribis acted at least in part as Trump's personal agent, so Ribis's Nevada contacts could be attributed to Trump individually.
  4. Nevada could exercise specific personal jurisdiction over Trump because he purposefully directed conduct toward Nevada and purposefully availed himself of Nevada's laws, and GNLV's interference claim arose from or directly related to those contacts.
  5. Nevada did not have general personal jurisdiction over Trump because he lacked continuous and systematic contacts with Nevada.
  6. Exercising specific personal jurisdiction over Trump in Nevada was reasonable and did not offend traditional notions of fair play and substantial justice.

Questions Presented

  1. Whether a writ of prohibition was an appropriate remedy to review the district court's refusal to quash service of process for lack of personal jurisdiction.
  2. Whether GNLV made a prima facie showing that Ribis acted as Trump's personal agent, permitting Ribis's Nevada contacts to be attributed to Trump individually.
  3. Whether Nevada could exercise general or specific personal jurisdiction over Trump consistent with the Nevada long-arm statute and federal due process.
  4. Whether exercising specific personal jurisdiction over Trump would be unreasonable or offend traditional notions of fair play and substantial justice.

Disposition

writ_denied

Cases Cited (17)

  • Budget Rent-A-Car v. District Court, 108 Nev. 483, 835 P.2d 17 (1992)(followed)
  • Price and Sons v. District Court, 108 Nev. 387, 831 P.2d 600 (1992)(followed)
  • Abbott-Interfast v. District Court, 107 Nev. 871, 821 P.2d 1043 (1991)(followed)
  • Levinson v. District Court, 103 Nev. 404, 742 P.2d 1024 (1987)(followed)
  • Boit v. Gar-Tec Products, Inc., 967 F.2d 671 (1st Cir. 1992)(followed)
  • Rano v. Sipa Press, Inc., 987 F.2d 580 (9th Cir. 1993)(followed)
  • Green v. McCall, 710 F.2d 29 (2d Cir. 1983)(followed)
  • Trident Construction v. West Electric, 105 Nev. 423, 776 P.2d 1239 (1989)(followed)
  • Grand Hotel Gift Shop v. Granite St. Ins., 108 Nev. 811, 839 P.2d 599 (1992)(followed)
  • World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 100 S. Ct. 559, 62 L. Ed. 2d 490 (1980)(followed)

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