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Civil Procedure — personal jurisdiction — minimum contacts

By: WISCONSIN LAW JOURNAL STAFF//February 19, 2014//

Civil Procedure — personal jurisdiction — minimum contacts

By: WISCONSIN LAW JOURNAL STAFF//February 19, 2014//

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United States Court of Appeals For the Seventh Circuit

Civil

Civil Procedure — personal jurisdiction — minimum contacts

Where a Wisconsin farmer has been to Illinois only once, Illinois courts lack personal jurisdiction over him.

“Greving lacks minimum contacts with Illinois that would permit the district court, consistent with the due process clause of the Fourteenth Amendment, to exercise specific personal jurisdiction over him. As relevant to this dispute, Greving only set foot in Illinois once—to attend a seed-corn meeting in Rochelle in early 2003, several months before the parties entered into the first of their grain contracts. It was there that he met Tom Wilson, who became his point of contact with Northern Grain. But even assuming that Greving’s attendance at this seed-corn meeting enters the personal-jurisdiction calculus for the later-formed contracts at issue here, there is no indication in the record that Greving attended the meeting in an effort to find grain buyers. And virtually everything else about Greving’s contractual relationship with Northern Grain was based in Wisconsin. When Greving met with Wilson, they met either at his Wisconsin farm or at a Denny’s restaurant in Delavan, Wisconsin. Greving delivered his Wisconsin-grown grain to a grain elevator in Wisconsin. Of course, the checks he received from Northern Grain were drawn on Illinois banks, but that does not show that he purposefully availed himself of the privilege of conducting business in Illinois. So although it may seem convenient as a practical matter for Greving to defend this suit in Rockford, the Constitution doesn’t permit the Illinois courts—and, thus, federal district courts in Illinois—to exercise jurisdiction over him.”

Affirmed.

12-2653 Northern Grain Marketing, LLC, v. Greving

Appeal from the United States District Court for the Northern District of Illinois, Reinhard, J., Sykes, J.

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