Mandeville v. Crowley, 695 F. App'x 357

Mandeville (Oklahoma resident) and Crowley married in New Mexico and executed a recorded separate property agreement in 2001 to keep Mandeville’s property (including two retirement accounts) separate.
Crowley moved to Texas and filed for divorce there in January 2014; she was represented by Texas attorney Vicki Pinak and the Pinak Law Firm.
Mandeville asserted the separate property agreement in the Texas divorce; on the eve of trial Crowley successfully moved to exclude evidence of the agreement and the Texas court awarded Crowley 100% of Mandeville’s retirement accounts; Mandeville’s appeal failed.
Mandeville sued Crowley, Pinak, and the law firm in federal court in Oklahoma under 42 U.S.C. § 1983 and state-law theories, alleging due-process violations, breach of the agreement, and tortious interference.
Defendants moved to dismiss for lack of personal jurisdiction; the district court granted the motion and dismissed without prejudice for lack of jurisdiction. Mandeville appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Oklahoma federal court had personal jurisdiction over Texas defendants for Mandeville’s § 1983 and state-law claims	Mandeville argued defendants’ service of the Texas divorce summons on him in Oklahoma and resulting harm in Oklahoma suffice for specific jurisdiction	Defendants argued their contacts were limited to Texas; the sole contact with Oklahoma was serving summons on Mandeville, which is insufficient for jurisdiction	Court held no personal jurisdiction: a one-time service on plaintiff in Oklahoma was an attenuated contact and did not create the substantial forum connection required for specific jurisdiction

Anzures v. Flagship Rest. Grp., 819 F.3d 1277 (10th Cir. 2016) (prima facie showing standard for jurisdictional facts decided on documentary record)
Dudnikov v. Chalk & Vermilion Fine Arts, Inc., 514 F.3d 1063 (10th Cir. 2008) (framework for statutory and constitutional personal jurisdiction analysis)
Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915 (2011) (standard for general jurisdiction—defendant must be essentially at home in forum)
Int’l Shoe Co. v. Washington, 326 U.S. 310 (1945) (minimum contacts and fair play standard for personal jurisdiction)
Walden v. Fiore, 571 U.S. 277 (2014) (specific-jurisdiction focus on defendant’s contacts with the forum, not plaintiff’s contacts)
Daimler AG v. Bauman, 571 U.S. 117 (2014) (limits on general jurisdiction over nonresident defendants)
Trujillo v. Williams, 465 F.3d 1210 (10th Cir. 2006) (§ 1983 does not authorize nationwide service of process)
Intercon, Inc. v. Bell Atl. Internet Solutions, Inc., 205 F.3d 1244 (10th Cir. 2000) (Oklahoma long-arm statute permits jurisdiction consistent with the U.S. Constitution)