Goetz v. LUVRAJ, LLC

Summary

The Supreme Court of Rhode Island affirmed enforcement of a Minnesota default judgment against LUVRAJ, LLC and Raju Chadha under Rhode Island's Uniform Enforcement of Foreign Judgments Act. The court held that Minnesota properly exercised specific personal jurisdiction based on the defendants' sales, internet advertising, communications, contract negotiations, and Minnesota choice-of-law provision. The defendants therefore failed to overcome the judgment's entitlement to full faith and credit.

Holdings

1. Defendants failed to show that the Minnesota District Court lacked personal jurisdiction, so Rhode Island was required to give full faith and credit to the properly entered Minnesota judgment.
2. Minnesota properly exercised specific personal jurisdiction because defendants purposefully directed substantial commercial and contractual contacts toward Minnesota and the claims arose from those contacts.

Questions Presented

1. Whether Rhode Island was required under the Full Faith and Credit Clause to enforce the Minnesota default judgment unless defendants established that Minnesota lacked personal jurisdiction.
2. Whether defendants' contacts with Minnesota, including sales to Minnesota customers, internet advertising, extensive contract negotiations with a Minnesota resident, and a Minnesota choice-of-law provision, satisfied Minnesota's long-arm statute and the Due Process Clause for specific personal jurisdiction.

Disposition

affirmed