A New York court may exercise specific jurisdiction over a foreign defendant pursuant to CPLR 302, which is New York's long-arm statute. CPLR 302(a)(1) provides that "a court may exercise personal jurisdiction over any non-domiciliary . . . who in person or through an agent . . . transacts any business within the state or contracts anywhere to supply goods or services in the state[.]" This jurisdictional inquiry is twofold: under the first prong the defendant must have conducted sufficient activities to have transacted business in New York, and under the second prong, the claims must arise from the transactions. In order to satisfy the second prong, the statute requires an articulable nexus or substantial relationship between the cause of action sued upon, or an element thereof, and the defendants' business transactions in New York. The inquiry is relatively permissive, and does not require causation. There must at least be a relatedness between the transaction and the legal claim such that the latter is not completely unmoored from the former, regardless of the ultimate merits of the claim. Therefore, under CPLR 302(a)(1), jurisdiction is proper even though the defendant never enters New York, so long as the defendant's activities here were purposeful and there is a substantial relationship between the transaction and the claim pled. Where this necessary relatedness is lacking, the claim as too attenuated from the transaction, or merely coincidental with it.
Aybar v. US Tires & Wheels of Queens, LLC, NY Slip Op 06099 (2d Dep't November 2, 2022)
