Rule of Law
A marriage is not rendered void under Connecticut law by virtue of the couple’s failure to obtain a statutorily required marriage license.

Facts
In 1955, Mr. Carabetta (defendant) and Mrs. Carabetta (plaintiff) exchanged vows in marriage before a Roman Catholic priest. They did not, however, obtain a statutorily required marriage license. They lived together and raised four children with all indications that they considered themselves legally married. Eventually Mrs. Carabetta filed for divorce. The trial court held that the marriage was void because the couple had never obtained a marriage license. The court then dismissed Mrs. Carabetta’s divorce petition for lack of subject-matter jurisdiction. She appealed.

Issue
Where a couple fails to obtain a marriage license but exchanges vows before a priest authorized to perform the marriage ceremony and then lives together and raises a family without any evidence that they do not consider themselves married, is the marriage void?

Holding and Reasoning (Peters, J.)
No. When the legislature has decided that the failure to meet a statutory requirement for marriage should render the marriage void, it has explicitly said so. For example, the law explicitly voids a marriage that is entered into between certain related persons. In contrast, the statute requiring a marriage license does not state that the failure to receive a license will make the marriage void. Rather, it states that the penalty for failing to obtain a license is a fine levied on the officiant who performed the marriage ceremony. This court has a long history of interpreting the absence of express statutory language. In line with such precedent, the court concludes here that a marriage entered into without a marriage license is dissoluble but not void. The court’s conclusion is supported by decisions in many other jurisdictions. Consequently, the trial court order is reversed.

Should the court grant the manufacturer’s motion to dismiss for lack of personal jurisdiction? Explain.

The first question is whether the court should grant the manufacturer’s motion to dismiss for lack of personal jurisdiction. The answer is yes, because the manufacturer lacks sufficient contacts with State B to support personal jurisdiction.

In general, a federal district court’s personal jurisdiction is the same as that of the state courts of general jurisdiction in the state where the federal court sits. A state court’s personal jurisdiction over a non-resident defendant is derived from the state’s long-arm statute, subject to the limits imposed by the Due Process Clause of the United States Constitution.

The manufacturer does not reside in State B, because it is incorporated in state A and has its principal place of business in State A. The painter must therefore rely on the State B long-arm statute, which permits personal jurisdiction to the limits of the U.S. Constitution. This, in turn, means that the manufacturer’s motion will depend on a due process analysis.

The Due Process Clause allows a state court to assert personal jurisdiction over a non-resident defendant who has sufficient minimum contacts with that state. The minimum contacts analysis examines the connections among the defendant, the forum state, and the litigation; the purpose is to determine whether the defendant has created connections with the forum state, such that the exercise of personal jurisdiction comports with traditional notions of fair play and substantial justice.

As part of this framework, personal jurisdiction can be divided into two types: specific jurisdiction and general jurisdiction. Specific jurisdiction applies where the cause of action arises out of the defendant’s contacts with the forum state. General jurisdiction applies where the defendant’s contacts with the forum state are so continuous and systematic that it can be sued there on any cause of action, even those that are unconnected to the forum.

The painter’s case against the manufacturer in State B does not involve specific jurisdiction, because none of the manufacturer’s contacts with State B had anything to do with the painter’s injury. Instead, the manufacture and sale of the ladder, plus the resulting injury, all occurred in State A. The painter must therefore rely on general jurisdiction to sue the manufacturer in State B.

The Supreme Court has held that general jurisdiction requires systematic and continuous contacts with the forum state, such that the defendant can be considered at home there. Examples of states with general jurisdiction include the state where the defendant is incorporated, and the state where the defendant has its principal place of business. The Court has not ruled out other grounds for general jurisdiction, but its recent cases appear to limit those grounds considerably. In Goodyear v. Brown, for example, the Court held that general jurisdiction did not exist where the defendant’s only connection with the forum was the sale of one industrial machine within that state. Further, in Daimler AG v. Bauman, the Court rejected a claim of general jurisdiction where the defendant’s only contact with the forum was a network of dealers.

These principles indicate that State B does not have general personal jurisdiction over the manufacturer. The manufacturer is incorporated and has its principal place of business in State A, not State B. The manufacturer’s sole contact with State B is a portion of its national dealer network, which accounts for only two percent of its annual revenue. The situation is directly analogous to Goodyear, which refused to find general jurisdiction based on minimal product sales. It is also analogous to Daimler, where a dealer network was held insufficient to support general jurisdiction. The vast majority of the manufacturer’s activities occur elsewhere, so in no sense can the manufacturer be said to be at home in State B. The federal court in State B therefore lacks personal jurisdiction over the manufacturer.

Not only does this conclusion align with Supreme Court precedent, but it is also consistent with traditional notions of fair play and substantial justice. Courts consider many factors to determine whether exercising personal jurisdiction is consistent with these notions, including: the burden on the defendant, the forum state’s interest in adjudicating the dispute, and the efficient operation of the interstate judicial system. These factors do not favor the painter’s attempt to sue the manufacturer in State B. The manufacturer’s home is State A, not State B, which suggests that litigating in State B will be less convenient for the manufacturer. Moreover, State B has no significant interest in adjudicating the case, because the case is based on events that occurred wholly in State A, before the painter moved to State B. Other than the painter’s personal convenience, judicial efficiency gains nothing by adjudicating the claim in State B. Indeed, it does not seem either fair or just to require a defendant to litigate in a state where none of the relevant events occurred, and where the defendant has little presence. Thus, traditional notions of fair play and substantial justice reinforce the conclusion that State B lacks personal jurisdiction over the manufacturer.

Nonetheless, the painter will argue that the painter’s own presence in State B should confer personal jurisdiction over the manufacturer. Specifically, the painter will contend that the manufacturer’s activities have caused an ongoing effect in State B, because the painter now lives there, and there he receives medical treatment arising from the accident. The painter will argue that this effect, in turn, is a meaningful contact that should be sufficient to support personal jurisdiction.

The painter will not prevail, however, because this very argument was rejected by the Supreme Court in Walden v. Fiore. In Walden, two plaintiffs, residents of Nevada, encountered a federal agent while traveling through Georgia, where the agent seized their property. The plaintiffs later sued the agent in Nevada. They argued that Nevada had personal jurisdiction because the agent’s activities, though carried out in Georgia, caused harm that continued to affect the plaintiffs in Nevada. The Court held that Nevada lacked personal jurisdiction over the agent, because the agent did not direct his actions specifically to Nevada. Rather, it was the plaintiffs’ own decision to be in Nevada that caused any effect to be felt within that state.

This case is analogous. The painter’s decision to move to State B was the painter’s alone, and had nothing to do with the manufacturer. The fact that the painter may continue to feel the effects of the injury and receive treatment in State B does not mean that the manufacturer ever directed its relevant conduct toward State B. As in Walden, the unilateral acts of the plaintiff cannot alone confer jurisdiction over the defendant.

The court should therefore grant the manufacturer’s motion and dismiss the case against the manufacturer for lack of personal jurisdiction.