Youngquist Bros. Oil & Gas, Inc. v. Miner
2017 CO 11
Colo.2017Background
- Miner, a Colorado resident, applied online from Colorado for a derrickhand job with Youngquist (a North Dakota corporation); Youngquist called, hired him by phone, and bought him a plane ticket to North Dakota.
- Miner completed employment forms and began work in North Dakota; he was injured there during his second shift and subsequently returned to Colorado.
- North Dakota denied Miner’s workers’ compensation claim; Miner then sought benefits under Colorado’s extraterritorial provision, § 8-41-204 (hired in Colorado and injured within six months).
- A Colorado ALJ awarded benefits and imposed a 50% statutory penalty on Youngquist for failing to carry Colorado workers’ compensation insurance.
- The Industrial Claim Appeals Office and the Colorado Court of Appeals affirmed; the Colorado Supreme Court granted certiorari and reversed, holding Colorado lacked personal jurisdiction over Youngquist.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Colorado can constitutionally exercise personal jurisdiction over a nonresident employer that hired a Colorado resident by phone and sent the worker to another state | Miner: Colorado may apply § 8-41-204 because he was hired in Colorado and injured within six months; Colorado has interest in protecting its residents | Youngquist: It lacked sufficient minimum contacts with Colorado (no offices, no targeted recruitment, hiring call was fortuitous), so due process bars jurisdiction | Held: No specific personal jurisdiction—Youngquist’s single phone hire and ticket purchase were random/fortuitous and did not constitute purposeful availment; Colorado cannot constitutionally subject Youngquist to the Act |
Key Cases Cited
- Int’l Shoe Co. v. Washington, 326 U.S. 310 (establishes minimum contacts test for personal jurisdiction)
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (clarifies purposeful availment and relatedness for specific jurisdiction)
- Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408 (limits bases for general jurisdiction)
- Alaska Packers Ass’n v. Industrial Accident Comm’n, 294 U.S. 532 (upheld extraterritorial workers’ comp award but assumed jurisdiction; not dispositive for modern minimum-contacts analysis)
- Archangel Diamond Corp. v. Lukoil, 123 P.3d 1187 (Colo. 2005) (Colorado precedent applying minimum-contacts framework)
- Keefe v. Kirschenbaum & Kirschenbaum, P.C., 40 P.3d 1267 (Colo. 2002) (discusses purposeful availment and fairness factors)