Paul Grant, a 40-year-old resident of Florida, was referred by his regular physician in Florida to Dr. Michael Galloway at his specialty clinic in Atlanta, Georgia. Dr. Galloway recommended surgery and Grant consented. Surgery was performed on March 1, 2007. Following the surgery, Grant's left leg was paralyzed and painful. Dr. Galloway told Grant that the paralysis was a result of the surgery. Your firm was hired by Grant to represent him in a medical malpractice claim. Your attorney has asked you to let him know whether this case can be filed in the United States District Court for the Northern District of Georgia in Atlanta. Discuss which jurisdiction is proper.

Grant's cousin, Lawanda Howell, a citizen of New York, drove him to Georgia to his doctor's appointment. While driving from Georgia, Howell was involved in an automobile accident with Wayne Turner, a citizen of Georgia. After Howell returns to New York, Turner sues Howell in a Georgia state court. May the Georgia courts constitutionally exercise personal jurisdiction over Howell?