Shook v. Wilson

Summary

The New Mexico Supreme Court held that conspiracy-based specific personal jurisdiction is consistent with due process when the defendant actively and voluntarily joins a conspiracy, knows that a coconspirator will commit acts in or aimed at New Mexico, and those acts create minimum contacts related to the claims. Applying that standard de novo, the Court concluded that the plaintiffs’ allegations and exhibits did not establish the law firms’ active participation or actual knowledge of forum-directed conspiratorial acts, so the district court lacked personal jurisdiction and the law firms had to be dismissed. The Court limited prior New Mexico precedent by rejecting constructive knowledge and requiring intentional targeting of the forum; there were no separate opinions.