Joshua Properties, LLC v. D1 Sports Holdings, LLC, 130 So. 3d 1089

Snopek filed suit against St. Dominic Health Services, Dl MS, and Dl TN in Mississippi circuit court seeking various misappropriation and business-tort claims.
Dl TN moved to dismiss for lack of personal jurisdiction; the trial court granted the motion.
Snopek sought interlocutory review, asking whether Mississippi court has personal jurisdiction over Dl TN; the issue is whether long-arm jurisdiction applies to Dl TN.
In 2007 Snopek proposed a multi-use sports complex; a letter of intent was executed and later expired, but parties continued discussions.
Dl TN, a Tennessee LLC not qualified to do business in Mississippi, participated in forming Dl MS with St. Dominic and traveled to Mississippi for meetings.
The court held that Mississippi long-arm statute §13-3-57 applies and that Dl TN has sufficient minimum contacts, so personal jurisdiction satisfies due process.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Mississippi has personal jurisdiction over Dl Sports Holdings, LLC (Dl TN).	Snopek contends Dl TN did business and engaged in activities in Mississippi via LLC formation and in-state participation.	Dl TN argues it did not conduct substantial in-state business and that jurisdiction would be unfair and burdensome.	Yes; long-arm statute and due process satisfied.

Public Employees’ Retirement System v. Hawkins, 781 So.2d 899 (Miss. 2001) (long-arm procedures and equitable consideration in interlocutory appeals)
Phillips v. Estate of Jones ex rel. Phillips, 992 So.2d 1131 (Miss. 2008) (two-step due-process analysis under Mississippi long-arm statute)
Sorrells v. R & R Custom Coach Works, Inc., 636 So.2d 668 (Miss. 1994) (two-part analysis for adjudicating jurisdiction)
World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (U.S. 1980) (due process and fair play in jurisdiction)
Burger King Corp. v. Rudzewicz, 471 U.S. 462 (U.S. 1985) (minimum contacts and reasonableness in jurisdiction)
Horne v. Mobile Area Water & Sewer Sys., 897 So.2d 972 (Miss. 2004) (single in-state act can confer specific jurisdiction)
Med. Assurance Co. of Mississippi, Inc. v. Jackson, 864 F. Supp. 576 (S.D. Miss. 1994) (letters/telephone contacts sufficiency for minimum contacts)
ITL Int’l, Inc. v. Constenla, S.A., 669 F.3d 493 (5th Cir. 2012) (long-arm reach to nonresidents performing work in forum)
Roxco, Ltd. v. Harris Specialty Chemicals, Inc., 133 F. Supp. 2d 911 (S.D. Miss. 2000) (transient visits not sufficient for doing business)
Mladinich v. Kohn, 164 So.2d 785 (Miss. 1964) (nexus considerations pre-amendment to long-arm statute)