Waggaman v. Arauzo, 117 A.D.3d 724

Plaintiff, a New York resident, sues a Texas-licensed physician who treated his mother in Texas and Florida.
Plaintiff alleges the physician improperly prescribed drugs without direct examination or active monitoring, causing dependency and family damage.
Plaintiff sues for damages personally and as sole heir of Purcell, and for damages to Purcell.
Supreme Court dismissed the action for lack of personal jurisdiction under CPLR 3211(a)(8).
Court analysis relies on CPLR 302(a)(3) and due-process standards for minimum contacts, citing New York and Federal law.
US Supreme Court decision in Walden refined minimum contacts, emphasizing defendant's conduct as the basis for forum connection

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether NY courts have personal jurisdiction under CPLR 302(a)(3)(ii).	Purporting tortuous act outside NY created NY injury and NY consequences.	No intended NY connection; no substantial NY revenue or minimum contacts.	No, jurisdiction not established.
Whether the defendant's conduct satisfied due process under International Shoe after Walden.	Attenuated connections to NY violated due process.	Defendant's conduct in Texas/Florida does not sufficiently connect to NY.	No, minimum contacts not shown.

Penguin Group (USA) Inc. v. American Buddha, 16 NY3d 295 (2011) (discusses due-process and contacts for jurisdiction)
Paterno v Laser Spine Inst., 112 AD3d 34 (2013) (plaintiff bears burden to prove jurisdiction under CPLR 302)
O’Brien v Hackensack Univ. Med. Ctr., 305 AD2d 199 (2003) (personal jurisdiction considerations under CPLR 302)
Hermann v Sharon Hosp., 135 AD2d 682 (1987) (earlier location-based jurisdiction analyses)
International Shoe Co. v. Washington, 326 U.S. 310 (1945) (establishes minimum contacts standard)
J. McIntyre Machinery, Ltd. v. Nicastro, 564 U.S. — (2011) (redefines meaningful forum connection)
Walden v. Fiore, 571 U.S. 134 S. Ct. 1115 (2014) (limits where plaintiff's connection suffices for jurisdiction)