Melinda Booth Dogra and Jagdish Dogra v. Jane H. Liles

Summary

The Nevada Supreme Court considered whether a California vehicle owner was subject to personal jurisdiction in Nevada after her adult daughter drove the vehicle there and was involved in an accident. The court held that the daughter's unilateral use of the vehicle did not establish specific personal jurisdiction and that the owner's motion to consolidate the related cases did not waive her jurisdictional objection. The court reversed and remanded for the district court to determine, under agency principles, whether the insurer's filing of an interpleader action subjected the owner to Nevada jurisdiction.

Holdings

1. A nonresident vehicle owner is not subject to Nevada specific personal jurisdiction merely because the owner's adult child unilaterally drove the vehicle into Nevada and caused an accident there, when the owner did not specifically authorize or know of the Nevada use and had no other Nevada contacts.
2. Jane's motion to consolidate related cases did not constitute a request for affirmative relief and therefore did not waive her objection to Nevada's exercise of personal jurisdiction.
3. An insurer's Nevada interpleader action could subject its insured to Nevada personal jurisdiction if the insurer acted as the insured's agent, but the agency issue must first be decided by the district court.

Questions Presented

1. Whether Nevada could exercise specific personal jurisdiction over Jane based solely on her purchase of a vehicle for her adult daughter and her failure to restrict the daughter's use of the vehicle, when the daughter unilaterally drove the vehicle to Nevada.
2. Whether Jane waived her personal-jurisdiction objection by filing a motion to consolidate related cases.
3. Whether Jane's insurer's filing of a Nevada interpleader action subjected Jane to Nevada personal jurisdiction through an agency relationship.

Disposition

reversed_and_remanded