Husband and wife, John (plaintiff) and Jodelle Cannington (defendant), were living in Maryland when they separated. John moved to Virginia, where his parents also resided. Jodelle bore the couple’s son, and she and the son remained in Maryland. John provided financial support to both Jodelle and their child. The son often visited John and John’s parents in Virginia. Jodelle traveled to Virginia on occasion as well for personal business and to transport her son. In early 1999, Jodelle asked John to arrange a trip for her to Houston. John reserved a trip that required Jodelle to leave from Dulles Airport in Virginia. On a previous occasion, John had similarly arranged for Jodelle to fly from Dulles to Houston. If Jodelle had not left from Dulles, she would have driven to Virginia to leave her son with John’s parents. This time, however, as Jodelle arrived at Dulles for her flight, John had her served with a complaint for divorce, a determination of support and custody, and division of assets. Asserting that John had induced her to enter Virginia through trickery, Jodelle moved to dismiss on the ground that Virginia courts lacked in personam jurisdiction over her.