Plaintiff physician filed defamation action against physician and Georgetown University and various other defendants. Court erred in denying Georgetown's motion to dismiss based on lack of personal jurisdiction. Plaintiff claimed that defendants made false statements about Plaintiff's qualifications to receive physician of the year award which he received at ceremony from National Hemophilia Foundation. Georgetown's contacts with Illinois do not qualify as systematic and continuous operations rendering it "at home" in Illinois for purposes of general personal jurisdiction based on general business activities. Plaintiff failed to present sufficient evidence to rebut Georgetown's affidavits showing that defendant physician was not acting as its agent when he communicated his personal views to NHF. Thus, Plaintiff did not show that that Georgetown's conduct created necessary connection in Illinois to generate specific jurisdiction.(CARTER and SCHMIDT, concurring.)
Illinois Appellate Court
Civil Court
Defamation