Brook v. McCormley

Federal 7th Circuit Court
Civil Court
Personal Jurisdiction
Citation
Case Number: 
No. 16-4255
Decision Date: 
October 11, 2017
Federal District: 
N.D. Ill., E. Div.
Holding: 
Affirmed

Dist. Ct. did not err in dismissing plaintiff’s legal malpractice action against defendants-Arizona lawyers, where said dismissal was based on finding that Dist. Ct. lacked personal jurisdiction over defendants to consider plaintiff’s complaint. Illinois lacked requisite contacts with defendants so as to establish personal jurisdiction, where: (1) although plaintiff (Illinois citizen) sought out defendants’ legal services, subject matter of legal representation concerned land located in Arizona that was subject to Arizona law; and (2) all business done on behalf of plaintiff was done in Arizona by Arizona lawyers. Fact that contract governing attorney-client relationship, attorney fees arising out of said contract and plaintiff’s recognition of injury had ties to Illinois did not require different result.