State ex rel. Key Insurance Company, Relator v. The Honorable Marco A. Roldan, 587 S.W.3d 638

Key Insurance Co., a Kansas corporation, issued an auto policy to Takesha Nash (Kansas City, KS resident) covering a 2002 Kia driven by her father, Phillip Nash.
Phillip Nash was involved in a collision with Josiah Wright in Jackson County, Missouri; Key initially denied coverage.
Wright obtained an arbitration award of $4.5 million against Nash; the Jackson County court confirmed that award as a judgment.
Wright sued Key and Nash in Jackson County to collect policy proceeds; Nash cross-claimed against Key for bad-faith refusal to settle and breach of the duty to defend.
Key moved to dismiss for lack of personal jurisdiction; the circuit court denied the motion. Key sought a writ of prohibition from the Missouri Supreme Court; this Court issued a preliminary writ but ultimately quashed it, holding Nash’s pleadings sufficiently alleged Missouri long-arm jurisdiction and minimum contacts.

Issue	Plaintiff's Argument (Nash)	Defendant's Argument (Key)	Held
Whether Nash pleaded conduct falling within Mo. long-arm §506.500 (tort in Missouri)	Nash alleged Key had exclusive control of settlement decisions, denied coverage, acted in bad faith, and that the economic injury (excess judgment) occurred in Jackson County, MO	Key argued its denial occurred outside Missouri and that Nash failed to make a prima facie showing that Key committed a tort in Missouri	Court: Nash adequately pleaded a bad-faith refusal-to-settle tort that falls within §506.500 (tort in this state)
Whether Key has minimum contacts with Missouri to satisfy due process for specific jurisdiction	Nash: the tortious conduct (bad-faith refusal to settle) produced injurious consequences in Missouri where Nash resides and where the excess judgment was entered	Key: it has no purposeful contacts with Missouri; any effects in Missouri result from third parties (insured, claimant, courts), not Key’s own conduct	Court: Alleged tortious act in Missouri is a sufficient contact; exercising specific jurisdiction does not offend due process
Whether prohibition is appropriate to stop the circuit court from exercising jurisdiction	Nash: jurisdictional allegations are sufficient; prohibition not warranted	Key: lack of contacts makes the circuit court’s exercise of jurisdiction an overreach warranting prohibition	Court: Issuance of a writ of prohibition would be inappropriate; preliminary writ quashed

State ex rel. PPG Indus., Inc. v. McShane, 560 S.W.3d 888 (Mo. banc 2018) (two-prong test: long-arm statute then due process minimum contacts)
State ex rel. Cedar Crest Apartments, LLC v. Grate, 577 S.W.3d 490 (Mo. banc 2019) (courts evaluate pleadings to determine prima facie personal jurisdiction)
State ex rel. Hawley v. Midkiff, 543 S.W.3d 604 (Mo. banc 2018) (prohibition appropriate when lack of personal jurisdiction is clear)
State ex rel. Norfolk S. Ry. Co. v. Dolan, 512 S.W.3d 41 (Mo. banc 2017) (prohibition prevents trial court action where personal jurisdiction lacking)
Scottsdale Ins. Co. v. Addison Ins. Co., 448 S.W.3d 818 (Mo. banc 2014) (elements of bad-faith refusal-to-settle tort)
State ex rel. William Ranni Assocs., Inc. v. Hartenbach, 742 S.W.2d 134 (Mo. banc 1987) (single tortious act can support jurisdiction; plaintiff must make prima facie showing)
Andra v. Left Gate Prop. Holding, Inc., 453 S.W.3d 216 (Mo. banc 2015) (long-arm statute construed to the limits of due process)
Int’l Shoe Co. v. Washington, 326 U.S. 310 (U.S. 1945) (minimum contacts and due process framework)
Burger King Corp. v. Rudzewicz, 471 U.S. 462 (U.S. 1985) (relationship among defendant, forum, and litigation governs specific jurisdiction)
Walden v. Fiore, 571 U.S. 277 (U.S. 2014) (contacts must be defendant’s own acts creating a substantial connection with the forum)