Casey

INTRODUCTION

A husband and wife, both residents of Missouri, filed a lawsuit in Missouri state court against a California resident and California corporation for making deceptive and fraudulent representations to the couple in the course of providing them with adoption facilitation services. Although the California defendants were properly served with notice of the action, they did not respond, and a default judgment was entered. The Missouri couple then applied in San Diego Superior Court for entry of judgment on the sister state judgment. In response, the California defendants, now also judgment debtors, moved to vacate entry of judgment. They asserted the Missouri court’s exercise of personal jurisdiction over them violated their right to federal due process because they had insufficient minimum contacts with Missouri. The trial court agreed and granted the motion to vacate entry of the Missouri judgment. We reverse. Although the California defendants disagreed that “any allegation of fraud committed upon a Missouri resident establishes Missouri jurisdiction,” they did not challenge or refute the Caseys’ claims that they directed communications claimed to be fraudulent and…