Lawrence, H. v. Robland International, 2171 EDA 2016

Henry and Linda Lawrence sued multiple defendants after Henry Lawrence’s hand was injured by a rotating blade of a Robland table saw on May 3, 2013, while working in Pennsylvania.
Complaint (filed Oct. 28, 2015) alleged strict liability, negligence, and breach of warranty against 15 defendants, including several companies based in Belgium and the Netherlands.
Defendants located in Belgium/the Netherlands filed preliminary objections arguing lack of personal jurisdiction.
Following jurisdictional discovery and a hearing, the trial court sustained the preliminary objections and dismissed the claims against those foreign defendants for lack of personal jurisdiction (order entered June 8, 2016).
Appellants appealed, arguing Pennsylvania courts have specific personal jurisdiction over the foreign manufacturers because they shipped products to Pennsylvania dealers and listed a Pennsylvania dealer on their website; appellants did not adequately invoke any provision of the Pennsylvania Long‑Arm Statute in their briefs.
The Superior Court held appellants waived their specific‑jurisdiction argument by failing to (1) develop reliance on the Long‑Arm Statute in briefing and (2) properly distinguish specific versus general jurisdiction; court affirmed dismissal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether PA courts have personal jurisdiction over foreign manufacturers that shipped products to and listed a Pennsylvania dealer	Lawrence: foreign defendants purposefully directed activities at PA (shipments, dealer listing) -> specific jurisdiction	Defendants: insufficient PA contacts; challenge sustained	Waived by plaintiff for failing to invoke and analyze the Long‑Arm Statute; appeal denied
Whether exercise of jurisdiction would comport with fair play and substantial justice	Lawrence: jurisdiction would be reasonable and constitutional	Defendants: exercise would offend due process	Waived (Plaintiff did not carry burden on statutory authorization; due process analysis not reached substantively)

Sulkava v. Glaston Finland Oy, 54 A.3d 884 (Pa. Super. 2012) (plaintiff bears burden to prove personal jurisdiction once defendant objects)
Mendel v. Williams, 53 A.3d 810 (Pa. Super. 2012) (distinguishes specific and general jurisdiction and explains Long‑Arm analysis)
Schiavone v. Aveta, 41 A.3d 861 (Pa. Super. 2012) (two‑part test for specific jurisdiction: statutory authorization and due process)
Burger King Corp. v. Rudzewicz, 471 U.S. 462 (U.S. 1985) (minimum contacts and fair play/fundamental justice framework for specific jurisdiction)
Fletcher‑Harlee Corp. v. Szymanski, 936 A.2d 87 (Pa. Super. 2007) (personal jurisdiction may be waived during litigation)
Commonwealth v. Kane, 10 A.3d 327 (Pa. Super. 2010) (appellate briefing obligations and consequences of inadequate briefing)