Longines-Wittnauer Watch Co., Inc. v. Barnes & Reinecke, Inc., 15 N.Y.2d 443 (1965)
A non-domiciliary defendant is subject to personal jurisdiction in New York if it transacts business within the state and the cause of action arises from that business activity, or if it engages in a continuous and systematic course of doing business within the state.
Summary
Longines-Wittnauer Watch Co. sued Barnes & Reinecke, an Illinois corporation, in New York, alleging breach of contract and negligence related to the design and manufacture of machinery. The issue was whether New York courts had personal jurisdiction over Barnes & Reinecke. The Court of Appeals held that jurisdiction was proper because Barnes & Reinecke transacted business in New York by sending engineers to the state, engaging in substantial contract negotiations, and the cause of action arose from those activities. The court also discussed the “doing business” standard under CPLR 301 and 313, emphasizing the need for continuous and systematic activity within the state.
Facts
Longines-Wittnauer Watch Co., a New York corporation, contracted with Barnes & Reinecke, Inc., an Illinois corporation, for the design and manufacture of machinery to be used in Longines’s watch production. Negotiations leading to the contract occurred in New York. Barnes & Reinecke sent engineers to New York to discuss and finalize the contract terms. The contract was executed outside of New York. Longines alleged that the machinery was defective, leading to the lawsuit for breach of contract and negligence.
Procedural History
Longines-Wittnauer Watch Co. initiated the lawsuit in New York. Barnes & Reinecke contested personal jurisdiction. The Special Term court’s decision was not explicitly stated. The Appellate Division’s ruling was not explicitly stated. The Court of Appeals reviewed the case to determine whether New York courts had jurisdiction over the Illinois corporation.
Issue(s)
1. Whether the cause of action for tort arose itself from the transaction of any business by the third-party defendant within the State under CPLR 302 (subd. [a], par. 1).
2. Whether the activities of the third-party defendant meet the criteria prescribed by Tauza v. Susquehanna Coal Co. for “doing business” within the State.
Holding
1. Yes, because Barnes & Reinecke transacted business in New York through significant contract negotiations and the sending of engineers, and the cause of action arose directly from these activities.
2. The court did not rule on this directly, remanding for a determination of facts at Special Term.
Court’s Reasoning
The Court of Appeals determined that jurisdiction was proper under CPLR 302 (subd. [a], par. 1), which allows for personal jurisdiction over a non-domiciliary who transacts business within the state, provided the cause of action arises from that business activity. The court emphasized that Barnes & Reinecke’s activities in New York were purposeful and directly related to the contract that formed the basis of the lawsuit. The court considered the substantial contract negotiations conducted in New York and the presence of Barnes & Reinecke’s engineers in the state as key factors. Regarding