DISCLAIMER: The following unofficial case summaries are prepared by the clerk's office
as a courtesy to the reader. They are not part of the opinion of the court.
211917P.pdf 08/02/2022 Brothers and Sisters in Christ v. Zazzle, Inc.
U.S. Court of Appeals Case No: 21-1917
U.S. District Court for the Eastern District of Missouri - St. Louis
[PUBLISHED] [Kelly, Author, with Smith, Chief Judge, and Benton, Circuit
Judge]
Civil case - Trademarks. The Lanham Act does not authorize nationwide
personal jurisdiction, so the existence of personal jurisdiction in this
case depends on Missouri's long-arm statute and the federal Due Process
Clause; under Missouri law, plaintiff sufficiently alleged that defendant
had transacted business in the state and had committed a tortious act
within the state, thereby satisfying Missouri's long-arm statute; turning
to the due process analysis, defendant's contact with Missouri was limited
to a single t-shirt sale and this was not a sufficient basis on which to
exercise personal jurisdiction, as defendant could not reasonably
anticipate being haled into court in Missouri based on a single sale; the
dismissal of the suit is affirmed.