An Illinois resident, unhappy with the boat he purchased, sued the Florida boat manufacturer for breach of contract. The manufacturer moved to dismiss based on lack of jurisdiction by the Illinois trial court. That motion, decided solely on the papers, was granted. On appeal, the Second District Illinois Appellate Court ruled that in cases in which “the trial court decides the issue of personal jurisdiction based solely on documentary evidence, our review is de novo.”
In this case, even after viewing the conflicting documentary evidence in favor of plaintiff, the appellate court agreed that the Florida manufacturer did not have minimum contacts sufficient for jurisdiction in Illinois.