Cece-York v. Saturn of Stamford Inc.
Even if an employee visits Connecticut to give a lecture at Hartford Hospital, and the worker's employer sells products in Connecticut, a court may lack long-arm jurisdiction over the employee, pursuant to Connecticut General Statutes §52-59b. Allegedly, the plaintiff was injured in a motor-vehicle accident that involved a 1995 Saturn. The plaintiff brought a product liability suit against the dealership and various individual defendants, who worked at General Motors, alleging that the car seat was defective. Four of the individual defendants, who worked as engineers, moved to dismiss and argued that the court lacked jurisdiction. One of the individual defendants, David C. Viano, worked as a research engineer in the GM Research Laboratories division in Michigan. Viano visited Connecticut to give a lecture at Hartford Hospital and attended a meeting in Groton. Other than that, the court found that the engineers, who were residents of Michigan, lacked regular contact with the State of Connecticut and did not, to their knowledge, use a computer or computer network in Connecticut, conduct personal business, own property or work in Connecticut. Absent evidence that the engineers transacted business in Connecticut, the court held it lacked jurisdiction, pursuant to the long-arm statute, C.G.S. §52-59b. "[A]ccepting plaintiffs' analysis," wrote the court, "would lead to the absurd result that these and perhaps hundreds of other GM employees who worked in various capacities on the design, review or improvement of the car seat over the course of 30 or more years could be hauled into court in any state in the country solely by virtue of GM's national market for this allegedly defective product." The court also found that the engineers lacked sufficient minimum contacts with the State of Connecticut. The engineers lacked systematic or continuous contact with Connecticut and did not direct their conduct to the state. It would not be reasonable to require the engineers to defend their claims in Connecticut. The court granted the engineers' motion to dismiss.