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Etchebarne-Bourdin v. Radice

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Argued April 4, 2007

Before RUIZ and BLACKBURNE-RIGSBY, Associate Judges,and SCHWELB, Senior Judge.

This case, now before us for a second time, requires us to interpret the District of Columbia’s “long-arm” statute, D.C. Code § 13-423 (2001). The issues before us concern two subsections of the statute which authorize District of Columbia courts to exercise jurisdiction over non-resident defendants who “transact[] any business” in the District of Columbia, D.C. Code § 13-423 (a)(l); or who “caus[e] tortious injury in the District of Columbia by an act or omission outside of the District of Columbia if [they] regularly do[] or solicit[] business, engage[] in any other persistent course of conduct, or derive[] substantial revenue from goods used or consumed, or services rendered, in the District of Columbia.” Id. at § (a)(4). When the conduct of a defendant satisfies either one of these sections, the court may exercise personal jurisdiction only if “a claim for relief aris[es] from acts enumerated in [the statute].” Id. at § (b). Specifically, we address for the first time whether all of the requirements set out in subsection (a)(4) must be linked to the claim for relief in a particular case, to permit the exercise of personal jurisdiction. We hold that the nexus requirement under subsection (b), as applied to the basis for jurisdiction set out in subsection (a)(4), does not require that the claim arise from what we consider to be independent “plus factors.” These factors (e.g., a “persistent course of conduct” in the District of Columbia), are required for the purpose of ensuring that exercising jurisdiction over a defendant where the claim for relief is based on conduct outside the forum comports with due process. Because the trial court thought otherwise, and on the basis that there was no nexus between the defendant’s persistent course of conduct in the District and the medical malpractice action, dismissed the complaint for lack of jurisdiction over appellees, we reverse the judgment and remand the case for further proceedings.

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