## Facts

- Four attorneys practicing in the District of Columbia provided legal services in Washington, D.C. to two related business entities, Mideast Systems, Ltd. and a joint venture, in connection with a federal government contracts dispute.
- The attorneys alleged the corporate defendants did not pay for the legal services performed in the District.
- The attorneys sued in federal court in the District of Columbia for breach of contract to recover unpaid legal fees.
- The court allowed an amended complaint adding two New York residents—Dominick Cosentino (president of both businesses) and Etrusca Cosentino (controlling shareholder and treasurer of the joint venture)—as individual defendants.
- The amended complaint alleged the Cosentinos personally induced the attorneys to undertake and continue the representation by misrepresenting that the joint venture was properly incorporated and had assets, when it was allegedly not properly incorporated and was insolvent.
- Dominick and Etrusca Cosentino moved to dismiss the claims against them for lack of personal jurisdiction under the District of Columbia long-arm statute.

## Issues

1. Whether the District of Columbia long-arm statute, D.C. Code § 13-423(a)(1) and/or (a)(3), authorized personal jurisdiction over the nonresident Cosentinos for claims arising from their alleged forum-related conduct.
2. Whether exercising personal jurisdiction over the Cosentinos comported with due process, including minimum contacts and fair play.

## Decision

- The court denied the Cosentinos’ motion to dismiss for lack of personal jurisdiction.
- The court found the claims arose from conduct fitting within the long-arm statute, including transacting business in the District and alleged tortious conduct causing injury in the District through acts occurring in the District.
- The court held that asserting jurisdiction satisfied due process because the Cosentinos had purposeful, case-related contacts with the District and could reasonably anticipate being sued there.

## Legal Principles

- Under D.C. Code § 13-423, a District of Columbia court may exercise personal jurisdiction over a person, directly or through an agent, as to claims arising from transacting business in the District or causing tortious injury in the District by an act or omission in the District.
- The “arising from” requirement is met when the plaintiff’s claims are directly tied to the defendant’s forum-related dealings that generated the dispute.
- A single, claim-connected transaction or act in the forum can support statutory jurisdiction when sufficiently related to the cause of action.
- Due process permits jurisdiction when the defendant purposefully establishes minimum contacts with the forum and jurisdiction is consistent with fair play and substantial justice.
- When nonresident individuals engage forum counsel, direct forum-centered activities, and are alleged to have committed claim-related misrepresentations connected to services performed in the forum, those contacts can support personal jurisdiction for both contract and fraud claims.

## Conclusion

The court held that the District of Columbia could exercise personal jurisdiction over the nonresident corporate principals because the fee and fraud claims arose from their District-related dealings with local counsel and alleged misrepresentations connected to legal services performed in Washington, D.C., and because jurisdiction was consistent with due process.


Law Offices of Jerris Leonard, P.C. v. Mideast Sys., Ltd., 630 F. Supp. 1311 (D.D.C. 1986)