State v. North Atlantic Refining Limited, 160 N.H. 275

Summary

The Supreme Court of New Hampshire held that North Atlantic Refining Limited was subject to specific personal jurisdiction in New Hampshire in the State's MTBE groundwater-contamination lawsuit. The court concluded that North Atlantic's production and design of MTBE-containing gasoline for the northeastern United States market, together with shipments to New Hampshire, satisfied relatedness and purposeful availment requirements. The court also determined that exercising jurisdiction was fair and reasonable, and affirmed the denial of North Atlantic's motion to dismiss.

Holdings

1. North Atlantic's production and design of MTBE-containing gasoline for the northeastern United States market and the shipment of thirty-seven loads to a New Hampshire location were contacts that related to the State's claims for contamination-related injuries.
2. North Atlantic purposefully availed itself of the privilege of conducting activities in New Hampshire because it specifically produced and designed MTBE-containing gasoline for a northeastern United States market that included New Hampshire and voluntarily participated in the distribution system.
3. Exercising specific personal jurisdiction over North Atlantic in New Hampshire was fair and reasonable.

Questions Presented

1. Whether New Hampshire's long-arm statute and the Federal Due Process Clause authorized specific personal jurisdiction over North Atlantic.
2. Whether North Atlantic's contacts with New Hampshire were sufficiently related to the State's claims.
3. Whether North Atlantic purposefully availed itself of the privilege of conducting activities in New Hampshire under the stream-of-commerce-plus theory.
4. Whether exercising jurisdiction over North Atlantic was fair and reasonable under the applicable gestalt factors.

Disposition

affirmed