Miami Valley Fair Housing Center, Inc. v. Steiner and Associates, Inc., 3:08-cv-00150

This is a Fair Housing Act case brought by non-profit housing advocates against developers, builders, architects, and owners of multiple-town-center apartment complexes in Ohio, Wisconsin, Missouri, and other sites.
Thirteen Third-Party Defendants who worked on construction in Wisconsin and Missouri moved to dismiss for lack of personal jurisdiction; they had no Ohio offices, assets, or regular Ohio business.
Apartment Complexes at issue include Gilbert Court at the Greene (Ohio), Lofts at Zona Rosa (Missouri), Bayshore (Wisconsin), and two planned town centers in Virginia and Texas.
Plaintiffs allege the complexes lack accessible design features for people with disabilities in violation of the FHA.
The Sixth Circuit remanded for jurisdictional analysis; district court then considered and rejected personal jurisdiction over the thirteen Third-Party Defendants.
The court ultimately recommended dismissal without prejudice for these defendants, finding no Ohio long-arm basis or due process to support jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does Ohio’s long-arm statute authorize jurisdiction here?	Plaintiffs contend contacts in Ohio through contracts and related activities suffice.	Defendants argue no substantial Ohio contacts; activities occurred in Wisconsin/Missouri with Ohio as a contractual nexus only.	No jurisdiction under Ohio long-arm statute.
Do the alleged Ohio contacts arise from the defendants’ activities in Ohio?	Actions in Ohio (agreements, communications, and payments) connect to injuries in Wisconsin/Missouri.	Contacts were incidental or attenuated; injuries arose outside Ohio; not proximal.	No suitable ‘arising from’ relationship under Ohio law.
Is federal due process satisfied for specific jurisdiction over these nonresident defendants?	Defendants purposefully availed themselves by contracting with Ohio entities and conducting some Ohio-based steps.	Contacts were random/attenuated; not purposeful availment; action arises elsewhere.	Specific jurisdiction not established; due process not satisfied; dismissal warranted.

Calphalon Corp. v. Rowlette, 228 F.3d 718 (6th Cir. 2000) (purposeful availment not shown despite long-term agreement and Ohio-based focus)
Southern Machine Co. v. Mohasco Industries, Inc., 401 F.2d 374 (6th Cir. 1968) (three-part test for specific jurisdiction)
Kerry Steel, Inc. v. Paragon Indus., Inc., 106 F.3d 147 (6th Cir. 1997) (purposeful availment emphasized in minimum contacts analysis)
Neogen Corp. v. Neo Gen Screening, Inc., 282 F.3d 883 (6th Cir. 2002) (prima facie burden and reasonable-particularity standard for jurisdiction)
Reynolds v. Intl. Amateur Athletic Fed'n, 23 F.3d 1110 (6th Cir. 1994) (interstate communications alone insufficient for minimum contacts)
Goldstein v. Christiansen, 638 N.E.2d 541 (Ohio 1994) (transacting business requires more than passive form contacts; substantial connection needed)
Signom v. Schenck Fuels, Inc., 2007 WL 1726492 (S.D. Ohio 2007) (proximate cause requirement under Ohio long-arm statute)
Brunner v. Hampson, 441 F.3d 457 (6th Cir. 2006) (Southern Machine test applied to determine jurisdictional propriety)
Lak, Inc. v. Deer Creek Enters., 885 F.2d 1293 (6th Cir. 1989) (failure of any prong defeats exercise of jurisdiction)