Bradley v. BradleyÂ, 256 N.C. App. 1

Joshua and Jessica Bradley married in Bladen County, North Carolina in 2011 but lived abroad and in several U.S. states during their four-year marriage (Australia, London, New York, New Jersey).
The couple had two wedding ceremonies in North Carolina and used Jessica’s father's North Carolina address to receive some mail and boxed shipments while living abroad.
Before moving to London, Joshua arranged for marital and some separate property to be shipped to and stored in a rented storage unit in Fayetteville, NC (rented by Jessica’s father at Joshua’s direction); Joshua paid the storage fees for ~23 months.
After separation in June 2015 Jessica and the parties’ child returned to and have lived in North Carolina; Joshua remained in London.
Jessica filed for divorce, custody, support, alimony, and equitable distribution in New Hanover County (March 2016); Joshua moved to dismiss for lack of personal jurisdiction under Rule 12(b)(2). The trial court denied the motion and Joshua appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether North Carolina courts have personal jurisdiction over Joshua for support, alimony, and equitable distribution claims	North Carolina has jurisdiction because Joshua (1) married in NC, (2) used NC as a U.S. "home base" for mail, (3) sent and stored marital property in NC, and (4) orchestrated events leading Jessica and the child to reside in NC	Jurisdiction lacking: wedding alone insufficient; Joshua’s contacts with NC were limited/temporary; storage rental was in third party’s name; he did not reside, hold NC license, or file taxes in NC	Affirmed. Court found Joshua purposefully availed himself of NC by directing mail/shipments, storing marital property in NC and paying fees, attending NC ceremonies, and orchestrating events leading to residence there — contacts met Due Process minimum-contacts test

Miller v. Kite, 313 N.C. 474 (N.C. 1985) (welfare of child in forum insufficient to confer jurisdiction absent defendant’s purposeful contacts)
Kulko v. Superior Court of Cal., 436 U.S. 84 (U.S. 1978) (marriage alone does not supply personal jurisdiction over a nonresident spouse)
Sherlock v. Sherlock, 143 N.C. App. 300 (N.C. Ct. App. 2001) (nonresident with extensive procedural and financial ties to NC subject to jurisdiction despite limited physical presence)
Butler v. Butler, 152 N.C. App. 74 (N.C. Ct. App. 2002) (purchase/use of marital residence in NC and regular visits supported jurisdiction)
Lang v. Lang, 157 N.C. App. 703 (N.C. Ct. App. 2003) (continuous business and residency-related acts in NC can establish purposeful availment)
World–Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (U.S. 1980) (Due Process requires minimum contacts; forum interest and convenience alone cannot override lack of contacts)