Moris v. Invata Holdings, Inc., AC48428

The plaintiff, a Connecticut resident, sued Invata Holdings, a Pennsylvania corporation, arising from business and employment disputes tied to a shareholders' agreement and related corporate reorganization. 1
Invata Holdings moved to dismiss for lack of personal jurisdiction, arguing it lacked sufficient contacts with Connecticut. 2
The trial court found the Connecticut long-arm statute satisfied but held due process was not met because Invata Holdings lacked minimum contacts with Connecticut. 3
The plaintiff argued Invata Holdings purposefully availed itself of Connecticut through the shareholders' agreement, Connecticut counsel, Connecticut phone numbers, and subsidiary contacts. 4
The plaintiff also claimed the court should have considered Invata Holdings' alleged discovery misconduct as a basis for sanctions or reversal. 5
The Appellate Court affirmed, holding minimum contacts were lacking and discovery misconduct did not warrant relief. 6

Issue	Plaintiff's Argument	Defendant's Argument	Held
Specific personal jurisdiction over Invata Holdings 7	Invata Holdings purposefully availed itself of Connecticut through the agreement and related contacts.	Its contacts were too attenuated and centered in Pennsylvania, not Connecticut.	No specific jurisdiction; minimum contacts were not shown. 8
Attribution of subsidiary contacts 9	Invata, Inc./Invata, LLC contacts should be imputed to Invata Holdings.	Separate corporate entities prevent imputing subsidiary contacts to the parent.	Subsidiary contacts were not attributable to Invata Holdings. 10
Discovery misconduct and sanctions 11	Invata Holdings obstructed jurisdictional discovery and its appeal should be discounted or sanctioned.	No proper sanction basis existed and the issue was not preserved for such relief.	No reversible error; discovery allegations did not warrant relief. 12

North Sales Group, LLC v. Boards & More GmbH, 340 Conn. 266 (Conn. 2021) (contract jurisdiction requires totality-of-circumstances purposeful availment analysis 13)
Cogswell v. American Transit Ins. Co., 282 Conn. 505 (Conn. 2007) (plaintiff bears burden to establish personal jurisdiction and due process framework 14)
International Shoe Co. v. Washington, 326 U.S. 310 (U.S. 1945) (due process requires minimum contacts and fair play 15)
Adams v. Aircraft Spruce & Specialty Co., 345 Conn. 312 (Conn. 2022) (specific and general jurisdiction standards; only a select set of affiliations supports general jurisdiction 16)
Jackson v. Prince, 231 Conn. App. 568 (Conn. App. 2024) (factual findings on a motion to dismiss are reviewed for clear error 17)
Lyons v. Birmingham Law Office, LLC, 224 Conn. App. 758 (Conn. App. 2024) (telephone and mail contacts are insufficient absent purposeful forum projection 18)
SFA Folio Collections, Inc. v. Bannon, 217 Conn. 220 (Conn. 1991) (parent and subsidiary are separate legal persons for jurisdictional purposes 19)
Hersey v. Lonrho, Inc., 73 Conn. App. 78 (Conn. App. 2002) (subsidiary activity generally cannot support jurisdiction over a nonresident parent 20)
Gutierrez v. Mosor, 206 Conn. App. 818 (Conn. App. 2021) (appellate court reviews sanctions only for reasonableness of the trial court's ruling 21)