Erica Davis v. Cranfield Aerospace Solutions

Oral argument

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Source: CourtListener oral-argument corpus (CC0).

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• noting that we have never held that the distinction between purposeful direction and availment is “a hard-and-fast rule”
• noting that “remote actions taken to service a 14 contract in the forum state seldom lead to purposeful availment by themselves”
• stating that “there’s no need to adhere to an iron-clad doctrinal dichotomy 28 to analyze specific jurisdiction” and “to the extent Cranfield argues that we should only review Appellants’ tort claims under the purposeful direction test, we disagree”
• explaining there is no “hard-and-fast rule” and the 16 first prong “may be satisfied by purposeful availment,” “by purposeful direction,” or “by some 17 combination thereof”
• typically the purposeful availment analysis applies in suits sounding in contract and the purposeful direction analysis in tort, although is not “a hard-and-fast rule”
• “[W]hen considering specific jurisdiction, courts should comprehensively evaluate the extent of the defendant’s contacts with the forum state and those contacts’ relationship to the plaintiffs’ claims—which may mean looking at both purposeful availment and purposeful direction.”

Source: CourtListener parenthetical corpus (CC0).