Opinion by Judge Roger Titus.
Held: The U.S. District Court of Maryland may exercise personal jurisdiction over a non-resident defendant who enrolled foreign default judgments in Maryland.
American notified its insurance carrier of the default judgments and moved to set aside the default judgments in Illinois. The motion was denied. The insurance carrier denied American's request for coverage and commenced a declaratory judgment action against American and the plaintiff. The plaintiff filed a motion to dismiss for lack of personal jurisdiction, contending he had insufficient contacts with the state.
Under Maryland's long-arm statute a court may exercise personal jurisdiction over a person that "transacts any business or performs any character of work in the State." There must be some act by which the defendant purposefully avails itself of the privilege of conducting activities in the State. Based on the similarities between the purposeful availment when a judgment creditor enrolls a foreign default judgment and when a litigant files a lawsuit, the Court found that the plaintiff transacted business and engaged in purposeful activity in Maryland. The plaintiff expressly invoked the "benefits and protections of Maryland's laws" by enrolling the foreign judgments. Therefore, the Court found it could exercise personal jurisdiction under Maryland's long-arm statute.
The opinion is available in pdf.