Cohen v. Barnard, Vogler & Co.

OPINION

TOCI, Judge.

¶ 1 This appeal arises from the trial court’s refusal to exercise personal jurisdiction over a Nevada accounting firm and three individuals who performed an audit in Nevada. The issue is whether accountants who negligently or fraudulently perform an audit in Nevada for a Nevada client are subject to personal jurisdiction in Arizona. We hold that absent proof that the accountants purposefully created contacts with Arizona or purposefully directed their activities at Arizona residents, Arizona cannot subject them to personal jurisdiction.

I. BACKGROUND

¶ 2 In January 1994,…