ITL Int’l, Inc., et al. v. Constenla, S.A., et al.

Plaintiffs filed this declaratory judgment action in federal district court in Mississippi, seeking relief against their longtime Costa Rican distributor. The district court dismissed the complaint for lack of personal jurisdiction over defendants. The court held that, even if defendants could reasonably anticipate being haled into Mississippi federal court, they could not reasonably anticipate being so haled to answer claims such as these. Seeing no constitutionally adequate nexus between plaintiffs' claims and defendants' Mississippi contacts, the court concluded that plaintiffs have failed to present a prima facie case that a Mississippi district court could exercise specific jurisdiction over defendants. Accordingly, the judgment was affirmed.