Triplett ex rel. Triplett v. R.M. Wade & Co., 261 S.C. 419

Summary

The Supreme Court of South Carolina considered whether an Oregon corporation had sufficient contacts with South Carolina to support personal jurisdiction in two tort actions arising from an allegedly defective pipe coupler. The court held that the corporation’s marketing activities, distribution arrangements, product presence, and post-accident investigation established sufficient contacts consistent with due process, and it affirmed the denial of the motions to quash service and dismiss. The opinion includes a dissent arguing that the contacts were insufficient.

Holdings

1. Wade's contacts with South Carolina, including its longstanding effort to develop a market through a controlled distributorship and other marketing channels, the presence of its products and publications in the state, and its investigation of the accident, were sufficient to make the exercise of jurisdiction consistent with traditional notions of fair play and substantial justice.
2. Service under Section 10-424 was proper because Wade was transacting business in South Carolina and the actions arose in connection with that business.
3. The trial court's finding that Wade was transacting business in South Carolina could not be disturbed because it was supported by reasonable inferences from the evidence and was not shown to be controlled by legal error.

Questions Presented

1. Whether R.M. Wade and Company had sufficient contacts with South Carolina to permit in personam jurisdiction consistent with the Due Process Clause of the Fourteenth Amendment.
2. Whether service of process on the foreign corporation under Section 10-424 of the 1962 South Carolina Code was proper because Wade was transacting business in South Carolina.

Disposition

affirmed