A New Approach to Jurisdictional Analysis?

Authors

anon

Abstract

Plaintiff, a Washington corporation, is a general insurance broker procuring "hard-to-get" insurance exclusively for other brokers. Defendant, a California corporation, telephoned plaintiff requesting it to obtain insurance for Cisco Aircraft, Inc., a customer negotiating a crop and forest dusting contract. Plaintiff obtained high-risk, high-premium coverage through its London broker and wired defendant a binder. Cisco defaulted and coverage was cancelled. Plaintiff paid its London broker the earned premiums and sought recovery from defendant. Defendant was served pursuant to the Washington long arm statute. Defendant unsuccessfully challenged the jurisdiction of the court. Plaintiff received a $41,275.15 judgment because the jury found that defendant had agreed to pay the premiums. On appeal, the Washington Supreme Court affirmed. Held: Defendant "overtly performed acts making it a party to and participant in a business transaction in Washington .. ," and was therefore subject to the jurisdiction of Washington courts under the long arm statute as to that particular transaction. Griffiths & Sprague Stevedoring Co. v. Bayly, Martin & Fay, Inc., 71 Wash. Dec. 2d 667, 430 P.2d 600 (1967).

First Page

833

Recommended Citation

anon, Recent Developments, A New Approach to Jurisdictional Analysis?, 43 Wash. L. Rev. 833 (1968).
Available at: https://digitalcommons.law.uw.edu/wlr/vol43/iss4/18