The Seventh Circuit affirmed the dismissal of a legal malpractice claim on the ground that Illinois lacked personal jurisdiction over an Arizona lawyer and the Arizona firm where he worked. The court did a traditional personal jurisdiction analysis. It first noted that there were no allegations of general jurisdiction over defendants. As to specific jurisdiction, the court noted that the lawyer and law firm were engaged by an Illinois resident for representation related to Arizona land. The lawyer and law firm did not solicit the client and never traveled to Illinois. There were telephone and other contacts with the Illinois resident. Nonetheless, the court held that the lawyer did not create contact with Illinois sufficient to establish specific jurisdiction.
(This is for informational purposes and is not legal advice.)
Knaus v. Guidry, 389 Ill. App. 3d 804, 906 N.E.2d 644, 329 Ill. Dec. 446 (1st Dist. 2009)