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Gorton v. Nordlund12/6/2005
oes not automatically result in jurisdiction over the parent corporation and that each corporation's contacts with the forum state must be assessed to determine personal jurisdiction, which is what occurred in Scott.
Furthermore, in Keeton, the Supreme Court explicitly recognized that New Hampshire, like Minnesota, "has adopted a 'long-arm' statute authorizing service of process on nonresident corporations whenever permitted by the Due Process Clause" 465 U.S. at 774, 104 S.Ct. 1478, and in analyzing personal jurisdiction, the Supreme Court applied due-process principles, rather than rules of corporate law.
We agree with the district court that respondent has made a prima facie showing that Dorel and Dorel U.S.A. have sufficient minimum contacts with Minnesota so that exercising personal jurisdiction over them in a Minnesota court does not offend traditional notions of fair play and substantial justice. There is no dispute that DJG transacts business in Minnesota. The record indicates that DJG's directors are also Dorel directors and officers of Dorel U.S.A. and that the principal offices of Dorel U.S.A. and DJG are located at the same address. More significantly, Dorel describes DJG as one of its major divisions in the United States and acknowledges that it coordinates the businesses of each of its business segments, which each include several operating divisions. Dorel also is the sole owner of the patents and manufacturing licenses for its products, and it has been directly involved in regulatory matters that involve child booster seats and in decisions regarding products-liability insurance. Also, DJG's former CEO testified that he reported to Dorel's chief operating officer, who approved budgets, capital spending, and operating plans, and that when hiring for high-level positions at DJG, he consulted with both Dorel's chief executive officer and its chief operating officer. Finally, Dorel mortgaged Cosco property to secure a line of credit for a separate Dorel subsidiary.
When viewed in their entirety, these activities, like the activities of the corporations in Scott, indicate that although Dorel, Dorel U.S.A., and DJG are separate corporations, their business operations are interrelated, and the actual production and distribution of child booster seats is accomplished through these interrelated business operations. In light of the relationships among the corporations, it does not offend traditional notions of fair play and substantial justice for a Minnesota court to exercise personal jurisdiction over Dorel and Dorel U.S.A. in an action arising out of the sale of a booster seat in Minnesota.
Affirmed.
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