Waldman v. Levien

Citations

• 2023 Ohio 1584

Syllabus

LONG-ARM JURISDICTION – INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS – DUE PROCESS – R.C. 2307.382 (A)(6): The trial court did not err in dismissing plaintiff's complaint for intentional infliction of emotional distress for lack of jurisdiction where the allegations in the complaint did not show that defendant caused tortious injury in Ohio and that plaintiff's cause of action arose from that tortious conduct as required by R.C. 2307.382(A)(6) because those allegations did not, as a matter of law, rise to the extreme and outrageous level necessary for a prima facie case of intentional infliction of emotional distress. The trial court did not err in dismissing plaintiff's complaint for lack of jurisdiction where the Ohio court's assertion of jurisdiction over the nonresident defendant would not comport with the requirements of due process because defendant's only contact with Ohio was a phone call with plaintiff, the father of her client in a divorce action in another state, she did not purposefully avail herself of the privilege of acting in Ohio, and her actions did not have a substantial connection with Ohio to make the exercise of jurisdiction reasonable.