Thomas Jefferson University v. Romer

Dr. Tocci, the director of biogenetics at the University of Miami (UM) (defendant), took a blood sample from the mother of a child born with Tay-Sachs disease to check whether the mother was a carrier of the Tay-Sachs gene. Tay-Sachs is a rare, neurodegenerative, genetic disorder that typically results in death. Because of temporary staffing shortages at UM, Tocci sent the mother’s blood sample, along with a small selection of other samples, to Thomas Jefferson University (TJU) (plaintiff) in Pennsylvania for processing. There was no formal contract between UM and TJU, and there was no expectation that TJU would continue to process blood samples for UM on an ongoing basis. TJU furnished all reports to UM, and UM communicated the results to the patients in the ordinary course of business. TJU’s analysis and report on the mother’s blood sample incorrectly indicated that the mother was not a carrier of the Tay-Sachs gene and could safely have more children. The mother sued TJU and UM for negligence based on the incorrect test and report. The mother claimed jurisdiction over TJU under Florida’s long-arm statute. TJU moved to dismiss for lack of personal jurisdiction. The trial court denied TJU’s motion, holding that (1) Florida had statutory long-arm jurisdiction over TJU because TJU’s negligent conduct in Pennsylvania caused the mother injury in Florida; and (2) TJU had sufficient minimum contacts with Florida to satisfy constitutional due-process requirements. TJU appealed.