Gibbons v. Brown
Facts:
Defendant sued plaintiff's husband in Florida for an auto accident in Montreal two years prior. Plaintiff now sues defendant in Florida concerning the same accident.
Issue:
Does bringing a suit in a court allow one to be sued there?
Plaintiff's Argument:
Defendant has subjected herself to the personal jurisdiction of the Florida court by her prior lawsuit.
Rule:
A defendant must have substantial and not isolated activity within Florida to be subject to its courts' jurisdiction.
Reasoning:
Defendant sued years ago, but plaintiff was not a party to that lawsuit. That doesn't make defendant liable here to lawsuits from anyone forever. Defendant no longer substantial and not isolated activity within the state.
Holding:
No, one must have additional recent activity as well.
Takeaway:
States' long-arm statutes can impose further restrictions than just meeting due process.