Personal jurisdiction; Due process; Exercise of “specific jurisdiction”; Burger King Corp. v Rudzewicz; Calder v Jones; Johnson v Griffin; Walden v Fiore; Jurisdiction under Michigan’s long-arm statute (MCL 600.715(2)); Fair Debt Collection Practices Act (FDCPA); The Michigan Regulation of Collection Practices Act (MRCPA); Michigan’s Uniform Enforcement of Foreign Judgments Act (MUEFJA)

[This appeal was from the ED-MI.] The court held that the district court had personal jurisdiction over defendant-Robinson, Hoover & Fudge, PLLC (RHF), an Oklahoma law firm, on plaintiff-Ross’s FDCPA and MRCPA claims based on RHF’s garnishment actions aimed at his Michigan wages based on an Oklahoma default judgment where their conduct was expressly aimed at a Michigan resident. Ross and his former wife bought a used car in Oklahoma. After they divorced, Ross moved to Michigan. They failed to make the payments on the car and their creditor hired RHF to sue them for contract breach in Oklahoma. Ross defaulted. Using the Oklahoma default judgment, RHF submitted “a garnishment summons to the Oklahoma registered agent of Ross’s employer’s parent company. The parent company passed the garnishment summons to Ross’s employer, which began garnishing wages Ross earned in Michigan.” He then sued RHF in Michigan federal district court for violations of the FDCPA and the MRCPA. He argued that RHF had been required to domesticate the Oklahoma default judgment under Michigan’s MUEFJA. RHF alleged that the district court lacked personal jurisdiction, and the district court agreed, dismissing the case. On appeal, the court explained that because neither party requested an evidentiary hearing on the jurisdiction issue, Ross was only required to make a prima facie showing that personal jurisdiction existed. While the district court agreed with RHF that Walden controlled this case, the court disagreed, concluding it bore “a closer resemblance to Calder and Johnson than to Walden.” The court held that Ross made a prima facie showing RHF “‘purposefully directed’” its activities at him, a forum resident, “thereby purposefully availing itself of the privileges of conducting activities in Michigan.” The court noted unlike “the Walden plaintiffs, Ross did not experience his injury in Michigan merely because he made a unilateral choice to travel there after he was the victim of unlawful conduct outside the forum.” Rather, RHF targeted his Michigan earnings, and according to Ross, had “circumvent[ed] the MUEFJA” by failing to domesticate the Oklahoma default judgment. As to whether Michigan law authorized personal jurisdiction over RHF, the court noted it has held that MCL “600.715(2) is satisfied where the plaintiff alleges that the defendant engaged in tortious conduct outside the state that ‘has caused an adverse economic effect upon [the plaintiff] in Michigan.’ That plainly happened here.” Reversed and remanded.