Consipio Holding, BV v. Carlberg, 282 P.3d 751

Nevada courts may exercise personal jurisdiction over nonresident officers/directors who directly harm a Nevada corporation.
Consipio, a Nevada shareholder, filed derivative and injunctive claims against PRVT officers/directors for alleged self-serving conduct.
PRVT is Nevada-incorporated with its principal place of business in Spain; respondents are European residents who visited Nevada only sporadically.
District court granted motions to dismiss for lack of personal jurisdiction without an evidentiary hearing.
NRS 78.135(1) provides a statutory basis for suits against officers/directors for violation of their authority, and creates notice that such actions may be pursued in Nevada.
Court remands for further factual analysis to determine if jurisdiction over respondents is proper.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether district court may exercise personal jurisdiction over nonresident officers/directors	Consipio asserts sufficient minimum contacts due to direct harm to Nevada corporation	Respondents contend lack of Nevada contacts; no jurisdiction	Yes, jurisdiction may be exercised if conduct harmed Nevada and meets due process
Relation of NRS 78.135(1) to jurisdiction over officers/directors	Statute authorizes suits and provides notice; supports jurisdiction	Statute not automatically conclusive on jurisdiction	NRS 78.135(1) supports district court’s jurisdiction over officers/directors
Effect of Shaffer v. Heitner on jurisdiction	Shaffer does not bar jurisdiction where harm is to a Nevada citizen by Nevada corporation	Shaffer precludes jurisdiction absent state interest or explicit consent	Shaffer distinguished; no automatic bar where statute supports jurisdiction
Fiduciary shield doctrine applicability	Not applicable because Nevada long-arm reaches due process limits	Shield could shield personal liability	Fiduciary shield doctrine does not apply; long-arm reaches due process

Trump v. District Court, 109 Nev. 687 (Nev. 1993) (minimum contacts; specific jurisdiction; due process)
World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (U.S. 1980) (purposeful direction; reasonableness factors)
Mizner v. Mizner, 84 Nev. 268 (Nev. 1968) (due process and jurisdictional standards)
Burger King Corp. v. Rudzewicz, 471 U.S. 462 (U.S. 1985) (purposeful availment; fair play and substantial justice)
Internat. Shoe Co. v. Washington, 326 U.S. 310 (U.S. 1945) (general framework for jurisdiction)
Jarstad v. National Farmers Union, 92 Nev. 380 (Nev. 1976) (purposeful contact; harm to forum exposed by actions)
Emeterio v. Clint Hurt and Assocs., 114 Nev. 1031 (Nev. 1998) (reasonableness factors in jurisdiction)
Shaffer v. Heitner, 433 U.S. 186 (U.S. 1977) (limits of jurisdiction absent direct forum connection)
DeCook v. Environmental Sec. Corp., Inc., 258 N.W.2d 721 (Iowa 1977) (direct harm to domestic corporation; due process)
Davis v. Metro Productions, Inc., 885 F.2d 515 (9th Cir. 1989) (fiduciary shield not controlling when statute expands jurisdiction)