Facts
- Cook Associates, an executive placement firm, operated offices in Chicago and Massachusetts.
- A Lexington executive contacted Cook’s Massachusetts office seeking candidates for a sales management position.
- Cook sent candidate résumés and a fee schedule stating Lexington would owe a fee if it hired a submitted candidate.
- Candidate Gregg Hoegemeir interviewed in Chicago with Lexington and was offered a field sales manager job, which he declined.
- After Cook’s Massachusetts agent left and opened a new agency, Lexington contacted her and later hired Hoegemeir for a national sales manager position with materially different terms.
- Cook demanded a placement fee as the original referring agency; Lexington refused.
- Lexington was not licensed to do business in Illinois; its Illinois contacts included the Chicago interview and limited activities such as annual trade-show attendance.
Issues
- Whether Illinois’ long-arm statute allowed specific jurisdiction based on an Illinois contact when the fee claim did not arise from that contact.
- Whether Lexington’s Illinois activities were sufficiently continuous and systematic to constitute “doing business” and support general jurisdiction.
- Whether asserting jurisdiction would satisfy due process minimum-contacts requirements.
Decision
- The Illinois Supreme Court affirmed the appellate court, holding Illinois courts lacked personal jurisdiction over Lexington.
- The long-arm statute did not apply because Cook’s fee claim did not arise from the Illinois interview and declined job offer.
- Lexington was not subject to general jurisdiction because its Illinois activities were sporadic and limited, not “doing business” in Illinois.
- The trial court’s judgment for Cook could not stand because service should have been quashed for lack of jurisdiction.
Legal Principles
- Under the Illinois long-arm statute, specific jurisdiction based on transacting business in Illinois exists only for causes of action arising from that Illinois transaction.
- A contact in Illinois that does not result in the contract or obligation sued upon does not satisfy the statute’s “arising from” requirement.
- General jurisdiction over a foreign corporation requires continuous and systematic in-state activity; occasional trade-show participation and intermittent visits are insufficient.
- Statutory limits on jurisdiction may be more restrictive than constitutional due process; failure to meet the statute ends the jurisdictional inquiry.
Conclusion
Illinois could not exercise personal jurisdiction over Lexington because the placement-fee dispute arose from a later, materially different hiring arrangement that did not stem from the earlier Illinois interview, and Lexington’s limited Illinois activities did not amount to “doing business” supporting general jurisdiction.