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Michigan Courts May Exercise Jurisdiction Over Businesses that Have Few In-State Contacts

The Michigan Court of Appeals recently held that Michigan courts may exercise jurisdiction over businesses that have engaged in a single past transaction in the state and that subsequently ceased doing business here. In Larsen Services, Inc v. Nova Verta USA Inc., Case No. 306280 (Mich. Ct. App. May 14, 2013), the trial court dismissed a plaintiff’s complaint for lack of jurisdiction because the defendant was located in another state, was not registered in Michigan, did not regularly conduct business in Michigan, had no employees or property in the state, and the last significant contact with Michigan occurred in 2004. However, the Michigan Court of Appeals reversed, holding that a Michigan court may exercise jurisdiction over a business that transacts any business within the state. “[T]he use of the term ‘any’ by our Legislature ‘establishes that even the slightest transaction is sufficient to bring a corporation within Michigan’s long-arm jurisdiction.'” In this case, two transactions with a company headquartered in Michigan several years ago allowed the court to exercise jurisdiction over the defendant. The case indicates that courts are maintaining their long jurisdictional reach in an environment with increasingly mobile business models.

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