Johnson v. Ward
New York Court of Appeals
4 N.Y.3d 516, 797 N.Y.S.2d 33, 829 N.E.2d 1201 (2005)
- Written by Steven Pacht, JD
Facts
In October 1997, Daniel Ward (defendant) allegedly injured Roger Johnson and Monique White (plaintiffs) when Ward crashed his car into Johnson and White’s car. The accident occurred in New Jersey, but Ward, Johnson, and White all then lived in New York. At the time of the accident, Ward’s car was registered in New York, and Ward had a New York driver’s license. However, Ward moved to New Jersey in December 1997 and exchanged his New York license for a New Jersey license in 1998. In October 2000, Johnson and White brought a negligence suit against Ward in New York state court. Ward moved to dismiss the complaint, arguing that, as a domiciliary of New Jersey, he was not subject to personal jurisdiction in New York. Johnson and Ward responded that personal jurisdiction over Ward was founded on New York’s long-arm statute, Civil Practice Law and Rules (CPLR) § 302(a)(1), which provided that a New York court could exercise jurisdiction over a nondomiciliary if the nondomiciliary transacted business in New York and the cause of action arose from that transaction of business. The supreme court granted Ward’s motion to dismiss. Johnson and White appealed to the appellate division, which (over a dissent) reversed. Per the appellate division, Ward transacted business in New York by virtue of Ward’s New York license and registration, and there was a substantial nexus between Ward’s license and registration and Johnson and White’s claim. The dissenting judge disagreed, opining, among other things, that Ward’s New York license and registration were insufficiently connected to the New Jersey accident. The appellate division subsequently granted Ward leave to appeal.
Rule of Law
Issue
Holding and Reasoning (Graffeo, J.)
What to do next…
Here's why 832,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 46,500 briefs, keyed to 994 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.
