Determining that the sale of beer by Illinois corporations to an Alabama minor on the Internet occurred in Illinois, the U.S. District Court for the Northern District of Alabama held Feb. 10 that the single sale was insufficient minimum contact to establish personal jurisdiction over the defendant (Butler v. Beer Across America, D. Ala., No. CV99-H-2050-S, 2/10/00).

The plaintiff, Lynda Butler, asserted a claim under the Civil Damages Act, Section 6-5-70 of the Alabama Code, arising from the sale of beer to her son by the defendants, Beer Across America, Merchant Direct, and Shermer Specialties, all Illinois corporations. The act provides for a civil action by the parent or guardian of a minor against anyone who knowingly and illegally sells or furnishes liquor to the minor.