Hogue v. Hogue, 16 Cal. App. 5th 833

Hogue (plaintiff) filed for a domestic violence restraining order in California in Feb 2016 after returning from Georgia; she alleged decades of abuse and recent violent incidents in late 2015.
Defendant Jerry Hogue was served in Georgia and made a special appearance in April 2016 to move to quash for lack of personal jurisdiction; the trial court granted the motion.
Plaintiff appealed; she had not been served with notice of entry of the order and filed a timely appeal.
The record before the court consisted of defendant’s brief declaration denying California contacts and plaintiff’s unverified petition (alleging the staged mock-suicide video sent to her while she was in California) plus an unauthenticated printout of e-mails submitted by plaintiff’s counsel.
The trial court apparently discounted internet/email allegations as not being the basis of the petition and implicitly resolved disputed factual claims (e.g., historical California abuse) in defendant’s favor.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether California has specific jurisdiction over nonresident defendant based on conduct "specially regulated" by CA (Domestic Violence Protection Act) when defendant sent a mock‑suicide video to plaintiff in California	Hogue: the video and alleged abusive course of conduct caused effects in California and fall within the "special regulation" basis for jurisdiction	Hogue: denied significant California contacts; abuse occurred in Georgia and defendant lacked purposeful connections to CA	Court: The mock‑suicide video sent to a California resident is conduct subject to California's special regulation and established sufficient purposeful contacts for specific jurisdiction; vacated order quashing service and remanded
Whether plaintiff’s unverified/unauthenticated internet evidence (emails/printouts) could support jurisdictional findings	Hogue: counsel provided a sample of internet contacts and argued a continuing course of conduct directed at CA	Hogue: denied such contacts in verified evidence; trial court treated those internet allegations as unalleged/unsupported	Court: Unverified/unauthenticated email printouts and arguments were insufficient; only the video (admitted) supported jurisdictional finding

HealthMarkets, Inc. v. Superior Court, 171 Cal.App.4th 1160 (standard for reviewing personal jurisdiction; burden shifting)
Vons Companies, Inc. v. Seabest Foods, Inc., 14 Cal.4th 434 (due process minimum‑contacts framework)
Burger King Corp. v. Rudzewicz, 471 U.S. 462 (specific jurisdiction principles)
Schlussel v. Schlussel, 141 Cal.App.3d 194 (California may assert jurisdiction for harassing communications into the state)
Kearney v. Salomon Smith Barney, Inc., 39 Cal.4th 95 (application of California statutes to out‑of‑state conduct in certain contexts)
Pavlovich v. Superior Court, 29 Cal.4th 262 (passive web posting generally insufficient for jurisdiction)
In re Marriage of Nadkarni, 173 Cal.App.4th 1483 (contacts that disturb peace of mind can support restraining orders)
Sabato v. Brooks, 242 Cal.App.4th 715 (unwanted contacts can be sufficient even without explicit threats)
Hall v. LaRonde, 56 Cal.App.4th 1342 (appearance by counsel bears on reasonableness of exercising jurisdiction)