## Facts

- Frank Snowney, a California resident, reserved a room by telephone from California at a Nevada hotel operated by defendants, providing a credit card to secure the reservation.
- The reservation agent quoted a price of $50 per night plus room tax.
- At checkout in Nevada, Snowney’s bill included an additional $3 “energy surcharge.”
- Snowney alleged defendants imposed the energy surcharge on overnight guests without disclosing it during reservation-making or check-in, resulting in charges exceeding the quoted or advertised price.
- Defendants were Nevada hotel-casino operators with no hotels, employees, or bank accounts in California but derived a significant portion of their business from California residents.
- Defendants advertised extensively in California through billboards, newspapers, radio, and television.
- Defendants also maintained a toll-free telephone number and an interactive website that provided room quotes and allowed reservations; the website highlighted proximity to California and provided driving directions from California.

## Issues

1. Whether California courts may exercise specific personal jurisdiction over Nevada hotel operators with no physical presence in California when they heavily solicit California residents and accept the reservation giving rise to the plaintiff’s claims from California.
2. Whether the claims “arise out of or relate to” defendants’ California-directed solicitation and reservation activities when the hotel stay and alleged overcharge occurred in Nevada.
3. Whether exercising jurisdiction in California would be fair and reasonable under due process.

## Decision

- The California Supreme Court held California courts may exercise specific personal jurisdiction over defendants consistent with due process.
- Defendants purposefully directed activities at California residents through extensive in-state advertising and reservation systems (toll-free number and interactive website).
- Snowney’s claims arose out of or related to defendants’ forum-directed activities because the reservation and quoted price were obtained from California through defendants’ solicitation and contracting mechanisms.
- Exercising jurisdiction was fair and reasonable given California’s interest in protecting residents, the plaintiff’s interest in a convenient forum, and the reduced burden on defendants from modern communication and travel.
- The court affirmed the Court of Appeal’s reversal of the order quashing service and remanded for further proceedings.

## Legal Principles

- Specific personal jurisdiction requires: (1) purposeful availment or purposeful direction toward the forum, (2) claims arising out of or relating to the defendant’s forum contacts, and (3) a showing that jurisdiction is reasonable and comports with fair play and substantial justice.
- A defendant may purposefully direct activity at the forum through targeted advertising and transactional systems that solicit and contract with forum residents, even without physical presence in the forum.
- Relatedness is satisfied when the plaintiff’s claims are tied to the forum-directed solicitation and contracting conduct that produced the transaction at issue.
- Jurisdiction is not defeated merely because performance and injury occurred out of state when the defendant’s deliberate forum targeting materially generated the transaction and alleged harm.

## Conclusion

California could constitutionally exercise specific personal jurisdiction over Nevada hotel operators that deliberately solicited California customers and accepted the plaintiff’s reservation from California, where the plaintiff’s claims about undisclosed charges were connected to that solicitation and contracting and where litigating in California was reasonable.


Snowney v. Harrah’s Ent. Inc., 35 Cal. 4th 1054, 112 P.3d 28 (Cal. 2005)