The Indiana Court of Appeals recently affirmed that a northern Indiana feed and farm supply store can sue a Michigan man in Indiana court for unpaid seed bills. The Appellate Court ruled the court in LaGrange County has personal jurisdiction over Harold Walters, who lives just over the border in Michigan.
Walters ordered seed from Lima Elevator Co., in Howe, Indiana. He drove over the border to the elevator to pick up the seed. He allegedly failed to pay the elevator. The elevator filed suit against him in LaGrange County for not paying for the seed he purchased on credit. Walters moved to dismiss the lawsuit, claiming the Indiana court did not have jurisdiction over him, a Michigan resident. He claimed he did not have sufficient contacts with Indiana to bring himself under the court's power. The LaGrange County Circuit Court -- and the Indiana Court of Appeals -- disagreed.
Walters "purposely availed" himself of the privilege of conducting business in Indiana. The Court held this means he should have reasonably anticipated being brought into an Indiana court if he failed to pay his seed bill. State courts have personal jurisdiction over people who intentionally conduct business in that state, especially if the lawsuit in question is a result of the person's contacts and actions within the state.
The Court further noted that Walters' due process rights were not violated. While he is a Michigan resident, he lives less than 20 miles from the LaGrange County Courthouse. He entered into a contract with an Indiana business for the purchase of goods in Indiana. He removed those goods from Indiana and then allegedly failed to make the required payment.
This case (Walters v. Lima Elevator Company, Inc., Case No. 44A03-1609-CC-2214 (Ind. Ct. App. Sept. 26, 2017) is a good reminder to businesses and patrons alike -- if a person purposely avails himself of the privilege of conducting business in a state and then a lawsuit is filed based on that interaction, that state has jurisdiction over the person, even if he lives elsewhere.