State ex rel. State Treasurer v. Moody's Investors Service, Inc., 349 P.3d 979

Wyoming sued Moody's Investors Service, McGraw-Hill, and S&P for hundreds of millions in losses from allegedly false ratings on ABS, RMBS, and CDOs during 2007-2008.
Eight claims were alleged against the Rating Agencies under various theories, including fraud, negligent conduct, and Wyoming Securities Act violations.
The Rating Agencies moved to dismiss; discovery was limited but no evidentiary hearing was held.
The district court granted dismissal for lack of personal jurisdiction, distinguishing specific vs. general jurisdiction and finding no purposeful availment or targeting of Wyoming.
The district court also held Wyoming law claims did not establish jurisdiction and entered final judgment after Rule 54(b) certification for partial dismissal.
Wyoming appeals the dismissal of claims against the Rating Agencies for lack of personal jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court correctly applied the 'causing important consequences' test for specific jurisdiction	Wyoming contends the court erred by misapplying Black Diamond and not properly assessing 'causing important consequences'.	Rating Agencies argue the court correctly applied Burger King/Calder guidance and required purposeful availment or targeting.	No error; proper application of the framework found no purposeful availment or targeting.
Whether the district court erred in denying specific jurisdiction based on the absence of targeted conduct in Wyoming	Wyoming asserts ratings and communications targeted Wyoming investors, creating jurisdiction.	Rating Agencies contend no express aiming at Wyoming and no suit-related connection to the forum.	No; district court properly found no suit-related conduct directed at Wyoming sufficient for specific jurisdiction.
Whether Wyoming's securities act claims can create personal jurisdiction over the Rating Agencies	Wyoming argues the Act reaches any person connected to offers/sales of securities, supporting jurisdiction.	Rating Agencies maintain jurisdiction cannot rely on merits questions or expand due process via statute.	Not; substantive state law cannot expand due process jurisdiction; jurisdiction rests on due process, not merits discovery.

Black Diamond Energy Partners 2001-A Ltd. v. S & T Bank, 278 P.3d 738 (Wyo. 2012) (three-part test for specific jurisdiction; causing important consequences)
Cheyenne Publ'g, LLC v. Starostka, 94 P.3d 463 (Wyo. 2004) (guidance on burden and prima facie showing in jurisdictional review)
Walden v. Fiore, 571 U.S. 277 (U.S. 2014) (tested suit-related conduct and defendant-focused contacts for specific jurisdiction)
Burger King Corp. v. Rudzewicz, 471 U.S. 462 (U.S. 1985) (purposeful availment and minimum contacts standard)
Calder v. Jones, 465 U.S. 783 (U.S. 1984) (express aiming to forum state for personal jurisdiction)
Amoco Prod. Co. v. EM Nominee Partnership Co., 886 P.2d 265 (Wyo. 1994) (adopts general/specific jurisdiction framework)
Helicopteros Nacionales De Colombia, S.A. v. Hall, 466 U.S. 408 (U.S. 1984) (unilateral activities of third parties not sufficient for jurisdiction)
WorldWide Volkswagen Corp. v. Woodson, 444 U.S. 286 (U.S. 1980) (foreseeability alone is not sufficient for jurisdiction)