Ryan Contracting, Inc. v. Jag Investments, Inc.

The questions before this court are (1) whether the district court has personal jurisdiction over JAG in Ryan’s hen action and (2) whether the district court has personal jurisdiction over JAG in GMH’s cross-claim. With respect to the first issue, I concur with the majority’s decision declining to adopt a joint-venture service rule and that actual notice of the mechanics’ hen action without service is insufficient to subject a party to personal jurisdiction. However, there are additional theories of personal jurisdiction that were not considered by the courts below. The relevance and strength…