Lucas v. P & L Paris Corp., 2012 Ohio 4357

Lucas v. P&L Paris Corp. concerns personal jurisdiction over Thackray Crane Rental in Ohio.
Plaintiff Lucas worked on a Pennsylvania job site for Ohio-based P&L Paris; injury occurred in Pennsylvania.
Thackray provided crane services to P&L; contracting occurred outside Ohio; no Ohio work by Thackray.
Ohio entities had communications via mail/phone related to invoices; no contracts formed in Ohio.
Trial court dismissed for lack of personal jurisdiction; appellate court affirms after de novo review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Ohio has personal jurisdiction over Thackray	Thackray transacted Ohio business via Ohio-based dealings	Thackray did not transact business in Ohio; no contracts or work there	No, Ohio lacks jurisdiction over Thackray

U.S. Sprint Communications Co. Ltd. Partnership v. Mr. K's Foods, Inc., 68 Ohio St.3d 181 (1994) (long-arm jurisdiction framework under Ohio law)
Kentucky Oaks Mall v. Mitchell's Formal Wear, Inc., 53 Ohio St.3d 73 (1990) (transacting business includes negotiations and dealings)
International Shoe Co. v. Washington, 326 U.S. 310 (1945) (minimum contacts for due process)
Goldstein v. Christiansen, 70 Ohio St.3d 232 (1994) (broadly defines transacting business; highly fact-specific)
Calphalon Corp. v. Rowlette, 228 F.3d 718 (2000) (minimum contacts analysis for nonresidents)
N. Am. Software, Inc. v. James I. Black & Co., 2011-Ohio-3376 (2011) (factors for transacting business in Ohio)