Knight v. Woodfield
2011 Miss. LEXIS 6
| Miss. | 2011Background
- Woodfield and Dokka resided in Mississippi; Knight is a Louisiana resident who communicated with Dokka while she lived with Woodfield in Mississippi.
- Dokka and Knight exchanged hundreds of text messages, phone calls, and emails in early 2007, while Dokka resided in Mississippi.
- Woodfield and Dokka separated in April 2007 and divorced in July 2007; Dokka later moved to Louisiana and joined Knight.
- Woodfield filed suit in Harrison County, Mississippi for alienation of affections on January 15, 2008; Knight moved to dismiss for lack of personal jurisdiction.
- Trial court denied Knight’s dismissals; court granted interlocutory appeal; appellate court ultimately affirmed exercising jurisdiction.
- Mississippi long-arm statute extends to nonresidents who commit torts in whole or in part in Mississippi; alienation of affections recognized as a tort within the state.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether email, text, and cell phone contacts constitute minimum contacts. | Woodfield argues Knight's communications caused the alienation of affections and thus meet minimum contacts. | Knight contends contacts were not aimed at Mississippi and lacked purposeful direction. | Yes; minimum contacts satisfied. |
| Whether exercising jurisdiction would offend fair play and substantial justice. | Woodfield contends Mississippi has strong interest and convenient forum for a local resident. | Knight argues forum burden and lack of purposeful direction negate jurisdiction. | No; jurisdiction does not offend traditional notions. |
Key Cases Cited
- Horne v. Mobile Area Water & Sewer Sys., 897 So.2d 972 (Miss. 2004) (minimum contacts analysis guiding in-state harm from out-of-state actions)
- Int'l Shoe Co. v. Washington, 326 U.S. 310 (1945) (establishes minimum contacts requirement)
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985) (requires activities directed at forum residents and relation to litigation)
- Camp v. Roberts, 462 So.2d 726 (Miss. 1985) (long-arm extends to certain torts committed in Mississippi)
- Saunders v. Alford, 607 So.2d 1214 (Miss. 1992) (long-arm and tort analysis under Mississippi law)
- Estate of Jones v. Phillips, 992 So.2d 1131 (Miss. 2008) (forum interest in protecting residents and remedy)
- Fitch v. Valentine, 959 So.2d 1012 (Miss. 2007) (tort purpose and remedy for loss of consortium)