N.L.J. v. W.C.R., 98 So. 3d 1144

Mother filed a paternity/custody/support action on December 27, 2011.
Father, served in Louisiana January 3, 2012, appeared specially to challenge Alabama jurisdiction.
Father moved to dismiss for lack of personal jurisdiction on January 17, 2012; trial court denied February 7, 2012.
Father petitioned for writ of mandamus January 8, 2012 (timing in text indicates early 2012).
Mother’s complaint did not allege any Alabama-contacts basis; father was domiciled in Louisiana and never visited Alabama.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Alabama has in personam jurisdiction over the nonresident father.	Mother argues § 30-3A-201(8) via Rule 4.2 supports jurisdiction.	Father contends no minimum contacts with Alabama; no foreseeability of suit in Alabama.	No; no sufficient minimum contacts; mandamus granted.
Whether the trial court properly denied the motion to dismiss for lack of jurisdiction.	Mother asserts Alabama long-arm rules authorize jurisdiction.	Father asserts absence of contacts and service outside Alabama negate personal jurisdiction.	Incorrect denial; must dismiss for lack of personal jurisdiction.

Ex parte McNeese Title, LLC, 82 So.3d 670 (Ala.2011) (burdens and standards for proving jurisdiction in Alabama)
Ex parte DBI, Inc., 23 So.3d 635 (Ala.2009) (due-process limits on Alabama’s long-arm rule)
WorldWide Volkswagen Corp. v. Woodson, 444 U.S. 286 (U.S. Supreme Court 1980) (minimum contacts and foreseeability necessary for jurisdiction)
Coleman v. Coleman, 864 So.2d 371 (Ala.Civ.App.2003) (visiting the state insufficient for minimum contacts)
Sena v. Sena, 709 So.2d 48 (Ala.Civ.App.1998) (visits to Alabama do not establish jurisdiction)
Ex parte Covington Pike Dodge, Inc., 904 So.2d 226 (Ala.2004) (allocation of burden in jurisdictional challenges)
Ex parte Excelsior Fin., Inc., 42 So.3d 96 (Ala.2010) (jurisdictional analysis when complaint lacks basis)