Fred, a retired auto worker and resident of Indiana was involved in a substantial auto accident in Ohio. With damages to the other drive over $100,000. He was sued by the other driver, Ethel, a resident of Virginia, in a Virginia state court. Fred has never been to Virginia, has no business in VA and never had any contacts with Virginia.

Based on the information in the scenario, which of the following statements is correct?

a. Ethel should refile in OH or IN, where there is jurisdiction over Fred's person.

b. Subject matter jurisdiction is present in any state or federal court.

c. Fred can obtain a dismissal of the case because the court lacks jurisdiction over his person.

d. All of the above