Kulko and Personal Jurisdiction

The case we discussed in class is Kulko v. Kulko- I may have mistakenly said "Katko" in class.... here is the holding: ( I also embelished the facts!!)

Held: The exercise of in personam jurisdiction by the California courts over appellant, a New York domiciliary, would violate the Due Process Clause of the Fourteenth Amendment. The mere act of sending a child to California to live with her mother connotes no intent to obtain nor expectancy of receiving a corresponding benefit in that State that would make fair the assertion of that State's judicial jurisdiction over appellant. Pp. 436 U. S. 91-101.

(a) A defendant to be bound by a judgment against him must

"have certain minimum contacts with [the forum State] such that the maintenance of the suit does not offend 'traditional notions of fair play and substantial justice.'"

International Shoe Co. v. Washington, supra, at 326 U. S. 316, quoting Milliken v. Meyer, 311 U. S. 457, 311 U. S. 463. P. 436 U. S. 92.