Hardell v. Vanzyl, 102 Cal. App. 5th. 960 (2024)

Cailin Hardell sued Adrian Vanzyl among others for sexual assault and battery, sexual harassment and retaliation arising from an incident that occurred in Miami, Florida in March 2022.  Vanzyl moved to quash service of the summons of the complaint on the ground that he was a non-resident of California and that he had insufficient contacts with California at the time of the incident for the trial court to exercise jurisdiction over him.  The trial court agreed with Vanzyl and quashed service and denied Hardell’s request to conduct jurisdictional discovery.  The Court of Appeal agreed that the connection between Hardell’s claims against Vanzyl was too attenuated to support specific jurisdiction over him, but further held the trial court erred in failing to permit Hardell to conduct jurisdictional discovery to determine whether it could exercise general jurisdiction over him.  Cf. Bercy v. City of Phoenix, 103 F.4th 591 (9th Cir. 2024) (harassment claims involving conduct that allegedly occurred in part after plaintiff filed for bankruptcy belonged to the bankruptcy estate and not to plaintiff personally).