DVI, Inc. v. Superior Court

This opinion resolves three consolidated writ petitions. In case No. G030673, petitioner DVI, Inc. (DVI) challenges an order denying its motion to quash service of summons on the cross-complaint of Dale Pap-worth. In case No. G030770, DVI challenges an order denying its motion to quash service of summons on the third amended complaint of MedCap Credit Co., LLC (MedCap). In case No. G030772, petitioner Matthew Colasanti challenges an order denying his motion to quash service of summons on MedCap’s third amended cross-complaint. DVI and Colasanti assert lack of minimum contacts necessary to create personal jurisdiction in California.

In granting DVI’s writ petitions, we address the circumstances under which a parent holding company is subject to personal jurisdiction in California based upon the contacts of its wholly owned subsidiary. DVI is a holding company and is the parent of defendant DVI Business Credit, Inc. (DVIBC). DVI itself does no business and owns no property in California. DVIBC does business in California and does not contest personal jurisdiction here.

We agree with the analysis of Sonora Diamond Corp. v. Superior Court (2000) 83 Cal.App.4th 523, 540 [ 99…