John M. Kirby
Edwards v. Hackney -- Personal Jurisdiction
In Edwards v. Hackney, an unpublished decision from May 7, 2013, the Court of Appeals affirmed a ruling that North Carolina did not have personal jurisdiction over a Virginia resident, arising out of an accident occurring in Virginia. The plaintiff argued that North Carolina had jurisdiction because the defendant owned property in North Carolina four years prior to the accident, the defendant's wife worked in North Carolina, and the defendant presumably drives on North Carolina roads. The court held that these contacts, not related to the motor vehicle accident, were insufficient to confer jurisdiction over the defendant.