109 Ohio App. 3d 367 - Krutowsky v. Simonson’s Empirical Analysis

Citation profile

13 state decisions

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 20 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “When deciding whether a defendant falls within the reach of the long-arm statute, a court should consider three factors: “ ‘First, the defendant must purposely avail himself of the privilege of acting in the forum state or causing a consequence in the forum state. Second, the cause of action must arise from the defendant’s activities there. Finally, the acts of the defendant or consequences caused by the defendant must have a substantial enough connection with the forum state to make the exercise of jurisdiction over the defendant reasonable.’ ” Cincinnati Art Galleries v. Fatzie (1990), 70 Ohio App.3d 696, 699 , 591 N.E.2d 1336, 1338 , quoting S. Machine Co. v. Mohasco Industries, Inc. (C.A.6, 1968), 401 F.2d 374, 381 .”

   3 later decisions quote this exact passage
   e.g. Preferred Capital, Inc. v. Power Engineering Group, Inc. · 167 Ohio App. 3d 653 - Preferred Capital, Inc. v. Ferris Bros.

2. “The only intentional contact Simonson had with Ohio was the mailing of invoices and reports to Ohio and also calling Krutowksy in Ohio to occasionally give updates on the work. Such actions without more do not rise to the level of minimum contacts.”

   1 later decision quote this exact passage
   e.g. The Kroger Company v. Malease Foods Corp