Youngquist Brothers Oil & Gas, Inc., Petitioner v. Travis Miner and the Industrial Claim Appeals Office of The…

Summary

The court held that Colorado could not exercise personal jurisdiction over Youngquist because the employer’s only Colorado contacts were a responsive telephone call to a Colorado applicant and payment for his travel to North Dakota. Those contacts were random and fortuitous rather than purposeful availment, so Youngquist could not constitutionally be subjected to Colorado’s workers’ compensation statute or its penalty provision. The court also held that workers’ compensation cases use the same minimum-contacts analysis as other cases.