Question
Michaela Scott, who lives in the fictional state of Patagonia, loves to ski in Colorado. On the last day of her most recent trip to
Michaela Scott, who lives in the fictional state of Patagonia, loves to ski in Colorado. On the last day of her most recent trip to Colorado, Patty purchased fifty bags of her favorite snack, roasted hazelnuts, at a small locally-owned convenience store.
Peter Lion, the store owner, was thrilled to make such a large sale and teased Michaela about her apparently voracious appetite. Before the sale was completed, Michaela explained to Peter that she planned to resell some of the hazelnuts to her friends and neighbors back in Patagonia. Peter told Michaela that he visits Patagonia twice a year to see his elderly grandmother.
On the long drive between Colorado and Patagonia, Michaela started eating the hazelnuts. While driving across Kansas, Michaela became ill. She was so uncomfortable that she decided to stay at a hotel in Kansas for the night.
Fortunately, within 24 hours, Michaela recovered fully and continued the drive home. She did not go to the hospital or visit a doctor.
A few weeks later, Michaela hired a lawyer and filed a lawsuit against Peter Lion in Patagonia state court.
You represent Peter Lion. Based on the above information and the following statute, explain the arguments you might raise on Peter's behalf in support of Peter's motion to dismiss the case for lack of personal jurisdiction.
Patagonia Jurisdictional Statute 81. A person may be sued in this state for any claims arising from his or her ongoing business relationship with a citizen of this state.
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