It has been 12 years since this column last addressed in personam jurisdiction in the New York courts over out-of-state health care providers. During that time, New Yorkers have been subject to an onslaught of television, radio and print advertisements by hospitals and other medical caregivers from other states. Additionally, there has been expanded use of the Internet for both advertising and as a tool to establish and maintain relationships with patients. Over the same period, there have been several significant decisions addressing the issue of long-arm jurisdiction in the context of medical malpractice actions. This month’s column examines these decisions.

We first discussed personal jurisdiction over out-of-state health care providers in June 1998, and revisited it in August 2002.1 Before turning to recent developments, it is helpful to recall the controlling statutory provisions and how they have been applied in the medical malpractice actions.