The fact pattern
Read it twice before you look at the answer
A small manufacturer based in State A makes specialty widgets. It has no offices, employees, or property in State B, but it maintains an interactive website through which State B customers placed about 40 orders last year, shipped directly to State B. A State B buyer is injured by a defective widget and sues the manufacturer in State B court. The manufacturer moves to dismiss for lack of personal jurisdiction.
Try it before you scroll
Spend 15 minutes writing your own IRAC answer first — the model below is far more useful after you have committed to your own issue list. These issues are in the facts:
- Specific vs. general personal jurisdiction
- Minimum contacts and purposeful availment
- Whether the claim arises from the in-state contacts
- Fair play and substantial justice (fairness factors)
Model IRAC answer
One way to write it — not the only way. Compare it to yours.
Issue
Whether State B may exercise personal jurisdiction over an out-of-state manufacturer that has no physical presence in the state but made about 40 sales there through an interactive website, when the injury arises from one of those sales.
Rule
A court may exercise specific personal jurisdiction over a non-resident defendant if the defendant has minimum contacts with the forum such that suit does not offend traditional notions of fair play and substantial justice. Minimum contacts require purposeful availment — the defendant must have deliberately directed activities at the forum — and the claim must arise out of or relate to those contacts. If purposeful availment is shown, courts weigh fairness factors: the burden on the defendant, the forum state's interest, the plaintiff's interest in relief, and the interstate judicial system's efficiency. General jurisdiction, by contrast, requires contacts so continuous and systematic that the defendant is 'at home' in the forum.
Application
General jurisdiction does not fit: with no offices, employees, or property in State B, the manufacturer is not 'at home' there. The analysis is specific jurisdiction.
Purposeful availment is satisfied. The manufacturer did more than passively host a website; it operated an interactive site through which it accepted roughly 40 orders from State B customers and shipped goods directly into the state. Deliberately selling and shipping into a forum on a recurring basis is purposeful availment — the manufacturer reached out to State B's market and benefited from it, rather than having its product arrive there by the unilateral act of a third party. The claim also arises from those contacts: the buyer was injured by a widget sold through exactly this channel, satisfying the relatedness requirement.
On fairness, the burden on a small out-of-state manufacturer to litigate in State B is real, but State B has a strong interest in providing a forum for its injured residents, the plaintiff has an interest in convenient relief, and modern litigation reduces the burden of distance. The fairness factors do not defeat jurisdiction once purposeful, related contacts are established.
Conclusion
State B likely has specific personal jurisdiction. The manufacturer purposefully availed itself of State B by repeatedly selling and shipping widgets there through an interactive website, the injury arises from those sales, and the fairness factors do not make jurisdiction unreasonable. The motion to dismiss should be denied.
Verify before you rely on this. This is an original teaching example, not legal advice. Rules vary by jurisdiction and by your professor's framing — check every rule statement against your casebook and class notes before using it.
Now try it timed.
Open the IRAC Practice Gym, set a 15-minute timer, and write your own answer to this fact pattern. You get feedback that helps you think — never an answer written for you.