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FIRST-CITIZENS BANK AND TRUST COMPANY v. McDaniel

Citations: 197 S.E.2d 556; 18 N.C. App. 644; 1973 N.C. App. LEXIS 1965Docket: 7310SC439

Court: Court of Appeals of North Carolina; July 11, 1973; North Carolina; State Appellate Court

Narrative Opinion Summary

In the case of First-Citizens Bank and Trust Company v. William K. McDaniel et al., the North Carolina Court of Appeals deliberated on the issue of personal jurisdiction over nonresident defendants. The case revolved around the defendant's promise to repay a loan made by the plaintiff to the defendant's corporation, which raised questions about whether such an agreement could establish sufficient minimum contacts with North Carolina. Referencing Supreme Court precedents, notably International Shoe Co. v. Washington, the court examined whether the nonresident defendant had contacts with the forum state that satisfied due process requirements. The court determined that the execution or performance of a single contract within the state could indeed establish the necessary contacts for jurisdiction. Citing North Carolina's longarm statute, G.S. 1-75.4(5)a, the court found that the defendant's contractual obligations constituted a promise to pay for services performed in North Carolina. Consequently, the court affirmed its authority to exercise jurisdiction over the defendant, thereby upholding the trial court's decision without any error, with Judges Morris and Parker in agreement.

Legal Issues Addressed

Minimum Contacts Doctrine

Application: A single contract executed or performed in North Carolina was deemed sufficient to satisfy the requirement of minimum contacts for asserting jurisdiction.

Reasoning: The court noted that a single contract executed or to be performed in North Carolina could establish these minimum contacts sufficient for jurisdiction.

North Carolina Longarm Statutes

Application: The court utilized G.S. 1-75.4(5)a to assert jurisdiction over the nonresident defendant based on the defendant's promise to pay for services performed in North Carolina.

Reasoning: Under G.S. 1-75.4(5)a, personal jurisdiction is conferred in cases arising from promises to perform services within North Carolina or to pay for services rendered in the state.

Personal Jurisdiction over Nonresident Defendants

Application: The court applied the principle of 'minimum contacts' to establish personal jurisdiction over nonresident defendants, ensuring that it aligns with due process standards.

Reasoning: The court referenced key Supreme Court decisions that outline the framework for establishing in personam jurisdiction based on 'minimum contacts.'