Marc Harding d/b/a Harding Law Firm v. Rick Sasso d/b/a Indiana Spine Group

CourtSupreme Court of Iowa
DecidedDecember 15, 2023
Docket21-1666
StatusPublished

This text of Marc Harding d/b/a Harding Law Firm v. Rick Sasso d/b/a Indiana Spine Group (Marc Harding d/b/a Harding Law Firm v. Rick Sasso d/b/a Indiana Spine Group) is published on Counsel Stack Legal Research, covering Supreme Court of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Marc Harding d/b/a Harding Law Firm v. Rick Sasso d/b/a Indiana Spine Group, (iowa 2023).

Opinion

IN THE SUPREME COURT OF IOWA

No. 21–1666

Submitted November 16, 2023—Filed December 15, 2023

MARC HARDING d/b/a HARDING LAW FIRM,

Appellee,

vs.

RICK SASSO d/b/a INDIANA SPINE GROUP,

Appellant.

On review from the Iowa Court of Appeals.

Appeal from the Iowa District Court for Polk County, Jeanie Vaudt, Judge.

Interlocutory appeal from the denial of motion to dismiss suit for lack of

personal jurisdiction. DECISION OF COURT OF APPEALS VACATED; DISTRICT

COURT ORDER AFFIRMED AND CASE REMANDED. McDonald, J., delivered the opinion of the court, in which all justices

joined.

Brent R. Ruther of Aspelmeier, Fisch, Power, Engberg & Helling, PLC, Burlington, for appellant.

Jeffrey M. Lipman of Lipman Law Firm, West Des Moines, for appellee. 2

MCDONALD, Justice. Iowa attorney Marc Harding engaged Indiana doctor Rick Sasso to provide

expert witness services in a potential medical malpractice suit in Iowa. Things

did not go according to plan, and Harding filed this suit against Sasso in Polk

County, Iowa. Harding sought to recover all or part of the $10,000 retainer he

paid to Dr. Sasso plus additional damages. Dr. Sasso moved to dismiss the suit

for want of personal jurisdiction over him. The district court denied the motion,

and Dr. Sasso filed an application for interlocutory review. We granted the

application and transferred the case to the court of appeals. The court of appeals

reversed the district court and remanded the case with instruction to dismiss

the case. We granted Harding’s application for further review.

I.

A state’s authority to exercise jurisdiction over a nonresident defendant is

limited by both the Federal Constitution and state law. See Sioux Pharm, Inc. v.

Summit Nutritionals Int’l, Inc., 859 N.W.2d 182, 188 (Iowa 2015).

With respect to the Federal Constitution, the Supreme Court holds that

“[t]he Fourteenth Amendment’s Due Process Clause limits a state court’s power

to exercise jurisdiction over a defendant.” Ford Motor Co. v. Mont. Eighth Jud. Dist. Ct., 141 S. Ct. 1017, 1024 (2021). Under the Court’s Fourteenth

Amendment jurisprudence, a state’s authority to exercise jurisdiction over a

nonresident defendant “depends on the defendant’s having such ‘contacts’ with

the forum State that ‘the maintenance of the suit’ is ‘reasonable, in the context

of our federal system of government,’ and ‘does not offend traditional notions of

fair play and substantial justice.’ ” Id. (quoting Int’l Shoe Co. v. Washington,

326 U.S. 310, 316–17 (1945)).

With respect to state law, Iowa law provides that “[e]very corporation, individual, personal representative, partnership or association that shall have 3

the necessary minimum contact with the state of Iowa shall be subject to the

jurisdiction of the courts of this state.” Iowa R. Civ. P. 1.306. We have explained

that rule 1.306 authorizes the widest exercise of personal jurisdiction allowed

under the Supreme Court’s precedents interpreting the Fourteenth Amendment.

See Book v. Doublestar Dongfeng Tyre Co., 860 N.W.2d 576, 583 (Iowa 2015);

Sioux Pharm, Inc., 859 N.W.2d at 188; Ostrem v. Prideco Secure Loan Fund, LP,

841 N.W.2d 882, 891 (Iowa 2014). Because Iowa law allows for the exercise of

personal jurisdiction up to the federal constitutional limit, we focus on the

federal constitutional requirements for exercising personal jurisdiction.

The Supreme Court has “recogniz[ed] two kinds of personal jurisdiction:

general (sometimes called all-purpose) jurisdiction and specific (sometimes

called case-linked) jurisdiction.” Ford Motor Co., 141 S. Ct. at 1024. “A state

court may exercise general jurisdiction only when a defendant is ‘essentially at

home’ in the state.” Id. (quoting Goodyear Dunlop Tires Operations, S.A. v. Brown,

564 U.S. 915, 919 (2011)). General jurisdiction over a defendant allows a state

court to adjudicate any and all claims against a defendant without regard to

whether the claims relate to the forum state or the defendant’s activities in the

forum state. See id. In the paradigmatic case, an individual is subject to a state’s general jurisdiction if the state is his domicile. See id.

“Specific jurisdiction is different: It covers defendants less intimately

connected with a State, but only as to a narrower class of claims.” Id. The contact

necessary to support the exercise of specific jurisdiction is not great. The

defendant need only take “some act by which [he] purposefully avails [himself] of

the privilege of conducting activities within the forum State.” Id. (quoting

Hanson v. Denckla, 357 U.S. 235, 253 (1958)). “The contacts must be the

defendant’s own choice and not ‘random, isolated, or fortuitous.’ ” Id. at 1025 (quoting Keeton v. Hustler Mag., Inc., 465 U.S. 770, 774 (1984)). Even when the 4

defendant has sufficient minimum contact with the forum state, the forum state

has jurisdiction over the defendant for only a limited set of claims. Specifically,

the nonresident defendant can be sued in the forum state only when the

plaintiff’s claims “ ‘arise out of or relate to the defendant’s contacts’ with the

forum.” Id. (quoting Bristol-Myers Squibb Co. v. Superior Ct. of Cal., 582 U.S. 255,

262 (2017)).

If a nonresident defendant has sufficient minimum contact with the forum

state and the claim relates to the contact, the court may exercise personal

jurisdiction over the defendant only where it “would comport with ‘fair play and

substantial justice.’ ” Ostrem, 841 N.W.2d at 893 (quoting Cap. Promotions,

L.L.C. v. Don King Prods., Inc., 756 N.W.2d 828, 834 (Iowa 2008)). In making that

determination, courts focus on

“the burden on the defendant,” “the forum State’s interest in adjudicating the dispute,” “the plaintiff’s interest in obtaining convenient and effective relief,” “the interstate judicial system’s interest in obtaining the most efficient resolution of controversies,” and the “shared interest of the several States in furthering fundamental substantive social policies.”

Id. (quoting Cap. Promotions, 756 N.W.2d at 834). In conducting this analysis,

courts must be cognizant of not allowing jurisdictional rules to severely disadvantage a defendant. See Shams v. Hassan, 829 N.W.2d 848, 857 (Iowa

2013).

II.

Dr. Sasso moved to dismiss Harding’s petition for lack of personal

jurisdiction. A motion to dismiss for lack of personal jurisdiction is a special

proceeding that requires the district court to make findings of fact and

conclusions of law in resolving the motion. See PSFS 3 Corp. v. Michael P.

Seidman, D.D.S., P.C., 962 N.W.2d 810, 826 (Iowa 2021). It is the plaintiff’s burden to make a prima facie showing that the exercise of personal jurisdiction 5

is allowed. See id. In determining whether the plaintiff met that burden, the

district court must accept as true the allegations of the petition and the content

of any uncontroverted affidavits offered by the parties. See id.; see also Mass.

Sch. of L.

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Related

International Shoe Co. v. Washington
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Marc Harding d/b/a Harding Law Firm v. Rick Sasso d/b/a Indiana Spine Group, Counsel Stack Legal Research, https://law.counselstack.com/opinion/marc-harding-dba-harding-law-firm-v-rick-sasso-dba-indiana-spine-group-iowa-2023.