In Black Diamond Aviation Grp. LLC v. Spirit Avionics, Ltd., 70 Misc. 3d 823 (Sup. Ct. Suffolk Cnty. 2020), Justice James Hudson of the Suffolk County Commercial Division limited the reach of New York’s long-arm statute, CPLR 302, in granting a motion to dismiss for lack of personal jurisdiction where the contract at issue was negotiated via emails between Ohio and Connecticut and no business was performed in New York.  The plaintiff argued that the Court had jurisdiction over defendant pursuant to CPLR 302(a)(1), which provides, in pertinent part, that a party will be subject to the jurisdiction of New York courts if it is a non-domiciliary who transacts business within New York or contracts anywhere to supply goods or services in New York.  The plaintiff alleged that because the defendant’s subcontractor performed certain work in New York, the defendant was subject to jurisdiction under CPLR 302(a)(1).  In rejecting this argument, the Suffolk County Commercial Division follows a familiar line of U.S. Supreme Court jurisprudence limiting a court’s jurisdictional reach where the defendant has no connection to the forum state.
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