The Law School Authority

Beaty v. M.S. Steel Co. Case Brief

Summary of Beaty v. M.S. Steel Co.
401 F. 2d 157 (4th Cir. 1968)

Facts:

  • Plaintiffs Maryland residents
  • Defendant Alabama corporation
  • Plaintiffs injured in steel factory and blamed the machinery bought from the defendants
  • Defendants had no contact with Maryland other than the sale of this machine to the company that employed the plaintiffs

Procedure:

  • District Court of Maryland dismissed for want of jurisdiction.

Issue:

  • Can a federal court sitting in Maryland practice in personam jurisdiction over the defendants?

Holding:

  • No

Ruling Statute:

  • Maryland long-arm statute allows personal jurisdiction over a person or corporation causing tortuous injury in this state by an act or omission outside the State if he regularly does or solicits business in this State, engages in any other persistent course of conduct in this State, or derives substantial revenue from food or services used or consumed in this State.

Rationale:

  • Court cannot go beyond legislative provisions in order to establish jurisdiction.
  • “it is clear that at least where the legislature has acted, even though the statute may not go to the limits of due process, the court of a state may not go further and assert jurisdiction over persons not embraced within that legislation.
  • The trial court may not exercise more jurisdiction than the statue allows


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