It’s a law geek’s dream: a personal jurisdiction case that overturns an older “mechanistic” standard with a functional, fact-dependent test.  The final result: who knows where the personal jurisdiction boundary lies!

In Robinson v. Harley-Davidson Motor Co. (S060226) the court  held that operating an interactive website that directs customers to an out of state motorcycle shop did not provide sufficient minimum contacts with Oregon to sue the motorcycle shop in this state.  Interestingly, the opinion of the court of appeals was reversed but the result was affirmed.  Because of intervening US Supreme Court caselaw, and the reliance on the “outer limits of due process” as the basis for personal jurisdiction, the Oregon Supreme Court abandoned the earlier standard of “substantive relevance”:

We too are persuaded that the substantive relevance test is mechanical and rigid. By requiring that at least one of a defendant’s contacts with the forum be relevant to the merits of a plaintiff’s claim, the substantive relevance test focuses exclusively on the “arise out of” aspect of the Supreme Court’s test requiring that an action either “arise out of” or “relate to” the defendant’s contacts with the state. The substantive relevance test creates a bright- line rule for what the Supreme Court has announced as a fact-specific inquiry into the reasonableness of state court jurisdiction.