## Facts

- Plaintiffs Roger Johnson and Monique White alleged injuries from a rear-end automobile collision on October 12, 1997, in New Jersey involving a vehicle driven by defendant Daniel A. Ward.
- At the time of the accident, all parties were New York residents; Ward had a New York driver’s license and a vehicle registered in New York.
- Ward moved to New Jersey in December 1997 and later obtained a New Jersey driver’s license.
- In October 2000, plaintiffs sued Ward in New York Supreme Court, New York County, for negligence arising from the New Jersey accident.
- Ward moved to dismiss for lack of personal jurisdiction under CPLR 3211(a)(8); plaintiffs relied on CPLR 302(a)(1), citing Ward’s New York license and registration.

## Issues

1. Whether CPLR 302(a)(1) permits New York long-arm personal jurisdiction over a nonresident for an out-of-state automobile accident based on the defendant’s New York driver’s license and New York vehicle registration.
2. Whether the negligence claim “arises from” any in-state transaction such that there is an articulable nexus or substantial relationship between the New York contacts and the tort claim.

## Decision

- The Court of Appeals reversed the Appellate Division and reinstated the trial court’s dismissal for lack of personal jurisdiction.
- The court held CPLR 302(a)(1) did not apply because the claim lacked a sufficient nexus to any business transaction in New York.
- The court rejected the view that possessing a New York driver’s license and vehicle registration, without more, established “transacting business” tied to the out-of-state accident.

## Legal Principles

- CPLR 302(a)(1) requires (1) a purposeful transaction of business within New York and (2) an articulable nexus or substantial relationship between that in-state transaction and the cause of action.
- A tort claim from an out-of-state automobile accident does not “arise from” New York activity merely because the driver was licensed in New York or the vehicle was registered there.
- Administrative contacts with New York (such as licensing or registration), standing alone, are insufficient where the alleged tortious conduct and injury occurred entirely outside the state.
- Long-arm jurisdiction cannot be extended beyond the statutory “arising from” limitation by treating unrelated background contacts as the basis for suit.

## Conclusion

New York courts lacked long-arm personal jurisdiction under CPLR 302(a)(1) over a defendant sued for a New Jersey automobile accident where the only asserted New York contacts were a New York driver’s license and New York vehicle registration, because the negligence claim did not arise from any in-state transaction.


Johnson v. Ward, 4 N.Y.3d 516, 797 N.Y.S.2d 33, 829 N.E.2d 1201 (N.Y. 2005)