Mitsubishi Motors Corp. v. Colemon: Broad Reading of Innovative Clinical Leads to General Personal Jurisdiction Under Georgia's Long-Arm Statute

Authors

• Benn C. Wilson, University of Georgia School of Law

Publication Date

2009

Abstract

In Innovative Clinical & Consulting Services, LLC v. First National Bank of Ames, the Georgia Supreme Court signaled a dramatic change in the interpretation of Georgia's jurisdictional Long-Arm Statute. The decision removed constraints that the Georgia Supreme Court saw as non-textual limitations that had been placed on Georgia courts' ability to exercise personal jurisdiction over nonresidents who transacted business in the state. In Mitsubishi Motors Corp. v. Colemon, the Georgia Court of Appeals took the unprecedented step of authorizing the exercise of general personal jurisdiction over a nonresident defendant when it concluded that jurisdiction over Mitsubishi was proper for claims arising out of a car accident that occurred in Honduras. According to the appellate court, under Innovative Clinical, Georgia courts were authorized to exercise general jurisdiction over nonresidents who transacted any business in the state under the Long-Arm Statute. This Recent Decision analyzes the Georgia Court of Appeals' decision in Mitsubishi Motors and the subsequent tension between the plain language of the Long-Arm Statute and other state appellate decisions. The commentary further questions whether the holding of Mitsubishi Motors followed inexorably from the Georgia Supreme Court's decision in Innovative Clinical.

Recommended Citation

Wilson, Benn C. (2009) "Mitsubishi Motors Corp. v. Colemon: Broad Reading of Innovative Clinical Leads to General Personal Jurisdiction Under Georgia's Long-Arm Statute," Georgia Law Review: Vol. 43: No. 4, Article 8.
Available at: https://digitalcommons.law.uga.edu/glr/vol43/iss4/8