New York Court of Appeals

Richard H. Ingraham v. James Carroll Et…

October 21, 199790 N.Y.2d 592

Summary

The New York Court of Appeals affirmed the dismissal of the wrongful‑death action because the plaintiff failed to establish personal jurisdiction over the Vermont physician under CPLR 302(a)(3). The majority held that neither clause (i) nor clause (ii) of the long‑arm statute was satisfied, even assuming the injury occurred in New York. Justice Bellacosa dissented, arguing that the physician’s regular referrals and revenue from New York patients satisfied the statutory requirements and that the case should proceed.