Knight v. Woodfield
| Docket Number: | 2009-IA-01371-SCT | |
| Supreme Court: | Opinion Link Opinion Date: 01-06-2011 Opinion Author: Carlson, P.J. Holding: Affirmed and remanded. |
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| Additional Case Information: |
Topic: Alienation of affections - Personal jurisdiction - Long-arm statute - Section 13-3-57 - Due process - Minimum contacts Judge(s) Concurring: Graves, P.J., Dickinson, Randolph, Lamar, Kitchens and Pierce, J.J. Dissenting Author : Waller, C.J. Dissent Joined By : Chandler, J. Procedural History: Interlocutory Appeal Nature of the Case: CIVIL - DOMESTIC RELATIONS |
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| Trial Court: |
Date of Trial Judgment: 08-10-2009 Appealed from: Harrison County County Court Judge: Robin A. Midcalf Disposition: Knight filed a motion to dismiss for lack of personal jurisdiction pursuant to Mississippi Rule of Civil Procedure 12(b)(2), which the county court denied. Case Number: D2401-08-69 |
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| Party Name: | Attorney Name: | |||
| Appellant: | William P. Knight |
CHAD PATRICK FAVRE |
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| Appellee: | Eric Woodfield | JOHN VERNON WOODFIELD |
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Synopsis provided by:  If you are interested in subscribing to the weekly synopses of all Mississippi Supreme Court and Court of Appeals hand downs please contact Tammy Upton in the MLI Press office. |
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| Topic: | Alienation of affections - Personal jurisdiction - Long-arm statute - Section 13-3-57 - Due process - Minimum contacts |
| Summary of the Facts: | Eric Woodfield filed a complaint alleging alienation of affections against William Knight, a Louisiana resident, in the County Court of Harrison County. Knight filed a motion to dismiss for lack of personal jurisdiction pursuant to M.R.C.P. 12(b)(2), which the county court denied. Knight filed a petition for an interlocutory appeal which the Supreme Court granted. |
| Summary of Opinion Analysis: | When determining whether a Mississippi court may exercise personal jurisdiction over a nonresident defendant, the court must consider whether the nonresident defendant is amenable to suit in Mississippi by virtue of our long-arm statute, section 13-3-57. If so, then the court must determine whether the nonresident defendant is amenable to suit in our state consistent with the Due Process Clauses of the state and federal constitutions. Mississippi’s long-arm statute extends to nonresident defendants who commit the tort of alienation of affections in Mississippi. The elements of the tort of alienation of affections are: wrongful conduct of the defendant; loss of affection or consortium; and causal connection between such conduct and loss. In his complaint, Woodfield alleged that Knight’s actions of texting, calling, and emailing Woodfield’s wife while she was in Mississippi were the direct and proximate cause of the alienation of affections. Taken as true, these allegations are sufficient to show that Knight committed the tort, in whole or in part, in Mississippi. Accordingly, the requirements of our long-arm statute are satisfied. Due process requires only that in order to subject a defendant to a judgment in personam, if he be not present within the territory of the forum, he have certain minimum contacts with it such that the maintenance of the suit does not offend traditional notions of fair play and substantial justice. A defendant has ‘minimum contacts’ with a state if the defendant has purposefully directed his activities at residents of the forum and the litigation results from alleged injuries that arise out of or relate to those activities. Knight’s actions originated in a neighboring state. From Louisiana, Knight called, sent text messages to, and emailed Woodfield’s wife. Importantly, Knight knew that she resided with Woodfield in their marital home in Mississippi. Knight and Woodfield’s wife exchanged more than 900 text messages in the course of two months. The two spent 980 minutes speaking to each other on the phone during the same time period. They also exchanged numerous emails, chronicling their developing relationship. Knight’s emails, phone calls, and text messages are sufficient “minimum contacts” with Mississippi for the purposes of our personal-jurisdiction analysis. Taking Woodfield’s allegations in his pleadings as true, Knight’s phone calls, emails, and text messages constitute the wrongful conduct that led to Woodfield’s alleged injuries. Thus, Knight’s actions constitute sufficient minimum contacts. Woodfield, a Mississippi resident, allegedly was injured and his marriage ended because of Knight’s alleged actions. Mississippi has an interest in providing a forum for its residents who are injured by nonresident defendants. Mississippi’s interest is enhanced because Louisiana does not recognize the tort of alienation of affections, making Mississippi the only viable forum for Woodfield’s claims. Woodfield also has a strong interest in adjudicating the dispute in Mississippi. By maintaining the suit in Mississippi, Woodfield may obtain convenient and effective relief for his claim. Further, the interstate judicial system’s interest in obtaining the most efficient resolution of controversies is not hampered by maintenance of the present suit in Mississippi. Knight is a resident of Louisiana, and maintenance of the suit in Mississippi will not create an extreme burden on him. Permitting claims for alienation of affections protects the marriage relationship and provides a remedy to those who have suffered loss of consortium as a result of the conduct of others. Thus, maintenance of this suit in Mississippi will not offend traditional notions of fair play and substantial justice. |
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