MASSACHUSETTS -

Massachusetts Supreme Judicial Court Applies “Transient Jurisdiction” Doctrine To Hold Nonresident Individuals’ Intentional, Knowing And Voluntary Presence In Massachusetts At Time Of Service Sufficient To Establish Personal Jurisdiction Even If Claims Have No Relationship To State -

In Roch v. Mollica, 481 Mass. 164 (2019), a member of a Massachusetts college softball team, a New Jersey resident, suffered injuries from an alleged hazing incident during a team trip to Florida at a property owned by the coach’s parents, who were New Hampshire residents. She sued the parents in Massachusetts Superior Court, alleging they “negligently allowed a dangerous act of initiation or hazing” and “negligently failed to obtain or seek immediate medical attention” for her, and served them when they later attended a softball game in Massachusetts. After defendants moved to dismiss for lack of personal jurisdiction, the trial court judge granted the motion, holding that service of process does not itself confer jurisdiction, as the two are distinct concepts and plaintiff’s claim otherwise had no connection to Massachusetts.