Catholic Diocese of Green Bay, Inc. v. John Doe 119

Summary

The Nevada Supreme Court considered whether Nevada courts had personal jurisdiction over the Catholic Diocese of Green Bay in a negligence action arising from alleged sexual abuse committed by a priest in Nevada. The court held that the Diocese lacked sufficient contacts with Nevada and that the Catholic doctrine of incardination did not establish an employment or agency relationship subjecting the Diocese to jurisdiction. The court reversed the judgment against the Diocese.

Holdings

1. Nevada courts lacked personal jurisdiction over the Diocese because it did not have sufficient contacts with Nevada and did not purposefully avail itself of Nevada's laws and protections.
2. Feeney's unilateral decision to seek employment in Nevada did not establish purposeful availment by the Diocese of Green Bay, and the Diocese's recommendation letter, phone call, and correspondence did not constitute purposeful contacts with Nevada.
3. The Catholic doctrine of incardination, including a priest's promise of obedience to the diocese in which he was ordained, did not conclusively establish an employment or agency relationship between Feeney and the Diocese of Green Bay.

Questions Presented

1. Whether Nevada courts had personal jurisdiction over the Wisconsin-based Diocese of Green Bay under Nevada's long-arm statute and the Due Process Clause.
2. Whether the Diocese's contacts with Nevada, including a recommendation letter, communications with the Diocese of Reno-Las Vegas, correspondence with Feeney, and the doctrine of incardination, established purposeful availment.
3. Whether incardination established an employment or agency relationship between Feeney and the Diocese of Green Bay sufficient to support personal jurisdiction.

Disposition

reversed