Ingraham v. Carroll, 90 N.Y.2d 592 (1997)

Under New York’s long-arm statute, CPLR 302(a)(3), jurisdiction cannot be asserted over a non-domiciliary defendant for a tort committed outside of New York unless the injury occurred within the state, and the defendant either engages in substantial in-state business or expects their actions to have consequences within the state while deriving substantial revenue from interstate or international commerce.

Summary

A New York resident sued a Pennsylvania doctor in New York for alleged medical malpractice occurring in Pennsylvania. The plaintiff argued that because he suffered financial consequences and continued pain in New York, the injury occurred in New York, thus satisfying the requirements for long-arm jurisdiction under CPLR 302(a)(3). The New York Court of Appeals held that the statute requires the actual injury to occur in New York, not merely consequential damages. Since the medical malpractice occurred in Pennsylvania, and the direct injury occurred there, New York lacked personal jurisdiction over the Pennsylvania doctor.

Facts

Plaintiff, a New York resident, underwent elective surgery performed by Dr. Carroll, a Pennsylvania physician, in Pennsylvania. Following the surgery, the plaintiff claimed to experience pain and complications. The plaintiff commenced a medical malpractice action against Dr. Carroll in New York, alleging negligence in the surgery performed in Pennsylvania.

Procedural History

The Supreme Court, Special Term, denied the defendant’s motion to dismiss for lack of personal jurisdiction. The Appellate Division affirmed. The New York Court of Appeals reversed, holding that New York courts lacked personal jurisdiction over the defendant.

Issue(s)

1. Whether the “injury” contemplated by CPLR 302(a)(3) requires the actual injury to occur within New York, or if consequential damages, such as pain and financial loss suffered in New York, are sufficient to establish jurisdiction.

Holding

1. No, because CPLR 302(a)(3) requires that the actual injury occur within New York for jurisdiction to be proper; the subsequent pain and financial consequences experienced by a New York resident in New York as a result of an out-of-state tort are insufficient to confer jurisdiction.

Court’s Reasoning

The Court of Appeals strictly interpreted the language of CPLR 302(a)(3), emphasizing the requirement that the tortious act committed outside the state must cause “injury to person or property within the state.” The court reasoned that the “place of the injury” is where the event producing the injury occurred, not where the resultant damages are felt. The court distinguished between the initial injury (the malpractice in Pennsylvania) and the subsequent consequences of that injury (pain, suffering, and financial loss in New York). The court stated that to interpret the statute otherwise would broaden its scope beyond what the legislature intended, potentially subjecting non-domiciliary defendants to jurisdiction in New York based solely on the plaintiff’s residency. The court acknowledged the remedial purpose of the statute but declined to expand its reach beyond its explicit terms, noting that the statute was intended to reach tortfeasors who purposefully conduct activities that have direct, in-state consequences. The court quoted Fantis Foods, Inc. v Standard Importing Co., 49 N.Y.2d 317, 326 (1980), stating residence of the injured party in New York is not sufficient to satisfy the statutory requirement of an “injury within the state.”