Fantis Foods, Inc. v. Standard Importing Co., 49 N.Y.2d 315 (1980)

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For a New York court to exercise long-arm jurisdiction over a non-domiciliary based on a tort committed outside the state, the injury within the state must be direct and not merely the indirect financial loss resulting from the injured party’s residence or incorporation there.

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Summary

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This case addresses the limits of New York’s long-arm statute, CPLR 302(a)(3), concerning jurisdiction over non-domiciliaries who commit torts outside the state causing injury within the state. Standard Importing, a New York corporation, sued Synergal, a Greek entity, for conversion of feta cheese in Greece. The court held that the fact that Standard was incorporated and had offices in New York was insufficient to establish jurisdiction because the direct injury (conversion) occurred outside New York, and any financial loss in New York was an indirect consequence. Therefore, New York courts lacked personal jurisdiction over Synergal.

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Facts

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Synergal, a Greek dairy cooperative, contracted to sell 1,200 barrels of feta cheese to Standard Importing, a New York corporation,