Switchback Group, Inc. v. Zweigle, 5:14-cv-01022

Switchback Group, Inc. contracted with John Zweigle (dba Design Services) as a mechanical designer from 2007, with design work and records to remain Switchback property and Switchback reimbursing travel to Ohio.
Zweigle traveled to Ohio several times per year over the seven-year relationship and both parties later reaffirmed/modified the contract (including an obligation to report business opportunities to Switchback).
Switchback sued for breach of contract and related claims, alleging Zweigle took credit for Switchback’s work and used it in his advertising after the contract ended.
Zweigle moved to dismiss for lack of personal jurisdiction, arguing the claims arose after the contract ended and he no longer had contacts with Ohio (he resides in California).
The district court treated the plaintiff’s burden as a prima facie showing, reviewed Ohio’s long-arm statute and constitutional due process requirements, and considered Zweigle’s repeated visits and contractual dealings with an Ohio corporation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Personal jurisdiction under Ohio's long-arm statute	Zweigle contracted to supply services in Ohio and his alleged post-contract misuse of Switchback work caused injury to an Ohio corporation, so jurisdiction arises under O.R.C. §2307.382	Claims arose after contract termination and thus do not arise from transacting business in Ohio; no continuing contacts	Court: Long-arm applies — contract formation/performance in Ohio and alleged injury to an Ohio corporation support jurisdiction
Constitutional due process (specific jurisdiction)	Zweigle purposefully availed himself of Ohio by contracting and repeatedly working for an Ohio company; the claims arise from those contacts and litigation in Ohio is reasonable	Litigation in Ohio is unduly burdensome because Zweigle lives in California and did not personally pay travel costs previously	Court: Due process satisfied — purposeful availment, claims arise from in-state contacts, and defending in Ohio is not unreasonable under the circumstances

Air Prods. & Controls, Inc. v. Safetech Int’l, Inc., 503 F.3d 544 (6th Cir. 2007) (two-step test: state long-arm and due process inquiry for personal jurisdiction)
CompuServe, Inc. v. Patterson, 89 F.3d 1257 (6th Cir. 1996) (plaintiff need only make a prima facie showing of jurisdiction)
Welsh v. Gibbs, 631 F.2d 436 (6th Cir. 1980) (court must view pleadings and affidavits in plaintiff’s favor at jurisdictional stage)
Schneider v. Hardesty, 669 F.3d 693 (6th Cir. 2012) (defendant must reasonably expect that actions would cause injury in forum state for long-arm §(A)(6))
Clark v. Connor, 82 Ohio St.3d 309 (Ohio 1998) (breach of in-state non-disclosure expectations supports suit in Ohio even if defendant moved out of state)
Bridgeport Music, Inc. v. Still N The Water Publ’g, 327 F.3d 472 (6th Cir. 2003) (purposeful availment requires more than passive activity)
Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985) (benefit/protection of forum’s laws supports requiring defendant to defend there)
Southern Machine Co. v. Mahasco Indus., Inc., 401 F.2d 374 (6th Cir. 1968) (three-part test for specific jurisdiction)