Alabama resident Lynda Butler sued Beer Across America, an Illinois firm, for having sold her minor son 12 bottles of beer. The son ordered the beer from the defendant's website while his parents were on vacation. Butler based her lawsuit on an Alabama statute and filed it in an Alabama state court. Exercising an option described in Chapter 2, the defendant removed the case to a federal court, the U.S. District Court for the Northern District of Alabama. Alabama's long-arm statute, rather than being restricted to certain listed behaviors on the part of nonresident defendants, contained an authorization for courts in the state and federal district of Alabama to exert in personam jurisdiction over nonresident defendants in any case in which the exertion of such jurisdiction would be consistent with the U.S. Constitution's due process guarantee. Beer Across America filed a motion asking the federal court to dismiss the case for lack of in personam jurisdiction.
The facts showed that Beer Across America owned no property in Alabama, had no offices or sales personnel located there, and did not advertise there. Beer Across America's $24.95 sale to Butler's son was the only sale made by the firm to him, and the firm had not directly solicited him as a customer. Sales to Alabama residents represented a very small percentage of Beer Across America's revenue. Beer Across America's website allowed the ordering of products but was not highly interactive in nature. In view of the facts and the relevant legal principles, how did the court rule on Beer Across America's motion to dismiss?

  • CreatedJuly 16, 2014
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