Samir M. Shams v. Sona Hassan
2013 Iowa Sup. LEXIS 41
Iowa2013Background
- Shams sued Hassan in Iowa for misappropriation of funds from an Iowa bank account.
- Hassan Maryland resident; Shams resided in Iowa in 2003; he left for Iraq and opened the Iowa account.
- Checks drawn on the Iowa account were given to Hassan for disbursement; Shams alleges she mishandled funds.
- District court dismissed for lack of personal jurisdiction; the court of appeals affirmed.
- Supreme Court of Iowa reversed, finding Hassan subject to Iowa jurisdiction and remanding for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Iowa may exercise specific jurisdiction over Hassan | Shams: contacts relate to misappropriation in Iowa | Hassan: no purposeful Iowa-directed contacts | Yes, sufficient contacts under Calder-based test |
| Do Hassan's Iowa-related activities satisfy Calder prongs 2 and 3 | Calder focal point on Iowa; intentional acts | Hassan: no targeting of Iowa | Yes, primary effects and focal point in Iowa established |
| Are minimum contacts balanced with fair-play considerations | Interest in providing relief and Iowa’s connection | Burden on nonresident; minimal impact | Jurisdiction reasonable; fairness satisfied |
| Do existing Iowa five-factor contacts tests apply given Calder analysis | Five factors support connections | Calder framework suffices; five-factor still useful | Calder framework controls; jurisdiction proper |
| Would exercise of jurisdiction be consistent with due process | Iowa has interest in adjudicating the dispute | Hassan burdened; rights weighed | Yes, jurisdiction constitutional |
Key Cases Cited
- World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (U.S. 1980) (foreseeability alone not enough for jurisdiction; fairness factors apply)
- International Shoe Co. v. Washington, 326 U.S. 310 (U.S. 1945) (establishes minimum contacts standard)
- Calder v. Jones, 465 U.S. 783 (U.S. 1984) (Calder effects test on intentional torts; focal point and harm in forum)
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (U.S. 1985) (purposeful availment and fair-play considerations; controls analysis)
- Capital Promotions, L.L.C. v. Don King Prods., Inc., 756 N.W.2d 828 (Iowa 2008) (Calder-based framework; five-factor test referenced; specific jurisdiction)