Statute Annotations › District of Columbia › D.C. Code § 13-423

D.C. Code § 13-423

Personal jurisdiction based upon conduct: the cases that interpreted this section

Jurisdiction
District of Columbia
Case notes
490
Cited in passing
82
Citing cases indexed
1,078
Case dates
1971–2026
Screened through
2026-06-24
Checked for later law changes
2026-10-20
Courts' treatment: live
No reviewed case has held this section invalid, preempted, superseded or repealed.
This reflects what the reviewed cases said, not legislative action: a later amendment or repeal by the legislature would not appear here unless a reviewed case discussed it.

572 citing cases reviewed of 1,078 in the citation index: 490 interpreted the section (annotated below), 82 cited it only in passing. Cases filed after 2026-06-24 may not have been reviewed yet.

Have a situation under D.C. Code § 13-423?

These notes show how courts have ruled. Ask about your specific facts and see which of these rulings apply, with citations you can check.

Other insufficient contacts

Section 13-423(a)(1) requires sufficient facts supporting personal jurisdiction over individual defendants based on their conduct in the District.

In re Chiquita Brands International, Inc. · filed 2016-06-01(a)(1)

The Court agrees that the amended complaints do not allege sufficient facts supporting the exercise of long-arm jurisdiction under either the D.C. or N.J, long-arm statutes, and further finds no compelling reason, at .this juncture of the litigation, to grant Plaintiffs’ alternative request for an opportunity to conduct jurisdictional discovery that might uncover evidence sufficient to support jurisdiction over the Individual Defendants in these jurisdictions.
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Section 13-423(a)(1)–(5) does not permit personal jurisdiction over nonresident defendants when their alleged conduct and the resulting injury lack the required connection to the District of Columbia.

Satterlee v. Commissioner of Internal Revenue · filed 2016-07-05(a)(1)–(5)

Neither the complaint nor plaintiff’s brief in support offers any jurisdictional allegations, and upon a review of both documents, it is clear that not one of the provisions of the long-arm statute is satisfied by the factual claims in this case.
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Section 13-423(a) permits personal jurisdiction over a nonresident defendant when the claim arises from specified business activity or tortious conduct connected to the District of Columbia.

Chandler v. Stover · filed 2016-09-30(a)

The complaint alleges no facts suggesting that these defendants transacted business, contracted to supply services, engaged in any other persistent course of conduct, or caused tortuous injury in the District of Columbia, and therefore, the plaintiff does not establish jurisdiction under the long-arm statute.
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Section 13-423(a) does not provide personal jurisdiction over nonresident defendants when the alleged conduct and claims have no connection to the District of Columbia.

Lemon v. Kramer · filed 2017-09-11(a)

Even making all reasonable inferences in Mr. Lemon’s favor, the Court finds that Mr. Lemon has failed to allege—much less meet his burden to show—that the District of Columbia’s long-arm statute applies to State Defendants or that this Court’s exercise of personal jurisdiction would satisfy the principles of constitutional Due Process.
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Section 13-423(a) permits personal jurisdiction over a nonresident defendant when the claim arises from specified business activity or tortious injury connected to the District of Columbia.

Fleming v. Iowa Board of Medical Examiners · filed 2017-11-22(a)

Pursuant to D.C. Code § 13-423(a), the district court may exercise personal jurisdiction over a non-resident defendant when a claim arises from the defendant’s “transacting any business in the District of Columbia,” “causing tortious injury in the District of Columbia by an act or omission in the District of Columbia,” or “causing tortious injury in the District of Columbia by an act or omission outside the District of Columbia if he regularly does or solicits business, engages in any other persistent course of conduct, or derives substantial revenue from goods used or consumed, or services rendered, in the District of Columbia.” Appellant has not demonstrated that any of the defendants in this case meet any of those conditions.
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Section 13-423 permits personal jurisdiction over a nonresident when the claim arises from specified conduct connected to the District; an allegation that the defendant missed a D.C. workshop did not establish a prima facie basis for jurisdiction.

Herbin v. Seau · filed 2018-07-11

Assuming that Seau is not domiciled in the District of Columbia, it is unclear from Herbin's complaint and other filings that she is subject to personal jurisdiction in the District of Columbia. ... Herbin, accordingly, has not made a prima facie showing of personal jurisdiction, which provides an additional basis for denying his motions for default judgment.
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Section 13-423 permits specific jurisdiction based on listed connections to the District; a defendant with no alleged District contacts does not qualify.

Canuto v. Carter · filed 2018-06-30(a)(1)-(5)

D.C. Code § 13-423 authorizes the exercise of specific jurisdiction under certain enumerated circumstances, including when an entity transacts any business in the District; contracts to supply services in the District; causes tortious injury in the District; or has an interest in, uses, or possesses real property in the District. D.C. Code § 13-423(a)(1)-(5). As explained above, Ms. Canuto has not alleged that Woodman-Sylvan has had any contacts with the District of Columbia.
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Section 13-423(a) requires a qualifying connection to the District of Columbia before a court may exercise specific personal jurisdiction over a claim.

Tracy v. Kratovil · filed 2019-04-29(a)

Here, the Tracys allege that they hired Kratovil to provide legal services in West Virginia. No facts are set out in their complaint, nor do the Tracys otherwise show, that Kratovil transacted business, contracted to supply services, or caused tortuous injury in the District of Columbia.
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Section 13-423 provides bases for specific personal jurisdiction, but none applied where the property and alleged events were in Texas.

Netis v. Sun West Mortgage Company · filed 2019-05-17

Likewise, no basis under the D.C. long-arm statute, D.C. Code § 13-423, applies to obtain specific jurisdiction.
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Section 13-423(a)(1) requires a claim to arise out of or relate to the defendant’s activities in the District for specific personal jurisdiction.

Africa Growth Corporation v. Republic of Angola · filed 2019-07-19(a)(1)

To establish personal jurisdiction under D.C. Code § 13-423, or to satisfy constitutional due process for specific personal jurisdiction, the alleged injuries must “arise out of or relate to” the jurisdiction-specific activities.
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Section 13-423(a) does not support specific personal jurisdiction when the plaintiff alleges none of the defendant conduct listed in the District’s long-arm statute.

Randle v. West Valley City Police Department (Of Utah) · filed 2019-07-23(a)

But Randle fails to allege that West Valley City engaged in any of the conduct enumerated in the District’s long-arm statute. See D.C. Code § 13-423(a).
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Section 13-423 requires a claim to arise from the defendant’s District of Columbia contacts to support specific personal jurisdiction.

Cherdak v. American Arbitration Association Inc · filed 2020-03-09

The Court finds that Plaintiffs have not met their burden to provide sufficient factual allegations that this Court has specific personal jurisdiction over the AAA. Plaintiffs have not shown that either of their claims arise from the AAA’s contacts with the District of Columbia.
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Section 13-423(a) requires a nonresident defendant to fall within one of its listed grounds before a court may exercise specific personal jurisdiction.

Lawyers United Inc. v. Roberts · filed 2020-06-29(a)

There is nothing to suggest that any one of the seven provisions of D.C.’s long-arm statute applies to these defendants. Because they do not fall within the District of Columbia’s long-arm statute, the Court lacks specific personal jurisdiction.
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Section 13-423(a) requires allegations supporting specific personal jurisdiction through the District’s long-arm statute.

Napolitano v. Powell · filed 2020-09-29(a)

Plaintiff contends, in passing and with little detail, that one of the four defendants lives in both Maryland and the District, but there are no allegations that he, or any of the other defendants, are domiciled in or maintain a principal place of business in the District of Columbia, see D.C. Code § 13–422, or that this court may exercise specific jurisdiction through the District’s long-arm statute, see D.C. Code § 13-423(a); see also Shafer v. Children’s Hosp. Soc’y of Los Angeles, 265 F.2d 107, 122 (D.C. Cir. 1959) (“Citizenship depends upon domicile, and, as domicile and residence are two different things, it follows that citizenship is not determined by residence.”).
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Section 13-423 permits specific personal jurisdiction based on conduct such as transacting business or causing tortious injury in the District, but requires facts connecting the defendant to the District.

Adler v. Loyd · filed 2020-10-14

The District of Columbia’s long-arm statute enumerates the circumstances under which courts in the District can exercise specific personal jurisdiction. See D.C. Code § 13-423. These circumstances include if the defendant transacts business or causes tortious injury here. See id. § 13-423(a)(1), (3). ... The Court lacks personal jurisdiction over Ms. Loyd and will grant her motion to dismiss.
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Section 13-423(a) requires facts connecting the defendant’s conduct and the claim to one of the listed grounds for specific jurisdiction.

Cannady v. Local Government Insurance Trust · filed 2021-06-21(a)

He has not shown that the court can exercise general jurisdiction over any Defendant, see D.C. Code § 13-422, and he has not alleged any facts that would establish specific jurisdiction under the long-arm statute, id. § 13-423.
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Section 13-423(a)(1), (3), and (4) requires facts connecting a nonresident defendant’s conduct to the District; federal employment at an agency headquartered there alone is insufficient.

Farmer v. Disability Program Manager · filed 2020-05-21(a)(1), (3), (4)

Neither has Farmer established personal jurisdiction under the District’s long-arm statute.
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Section 13-423 cannot support personal jurisdiction when the allegations underlying a petition have no connection to the District.

Nelson v. Burgemeister · filed 2022-02-03

Further, appellant fails to demonstrate any connection between the allegations underlying his petition and the ... District that would implicate the District’s long-arm statute.
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A defendant’s admission that she transacted business and had an interest in real property in the District can establish personal jurisdiction under § 13-423(a)(1) and (5).

Radbod v. Mohim Superior Court · filed 2022-02-17(a)(1), (5)

Although less direct, Masomeh implicitly conceded the Superior Court’s jurisdiction over her person under the long-arm statute, admitting in her answer that she had “transacted business” and had “an interest in real property” in the District of Columbia.
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Section 13-423(a) requires a plaintiff seeking specific personal jurisdiction to connect the claim to the defendant’s District contacts; an alleged District act must have caused a cognizable injury.

Han v. Financial Supervisory Service · filed 2022-07-05(a)

A plaintiff must demonstrate “that specific jurisdiction comports with the forums long-arm statute, D.C. Code § 13-423(a), and does not violate due process.” Id. (citation omitted). ... The relevant legal question for the Court is not whether “dismissal of the Ohio action based on the jurisdictional defect caused Plaintiff no material injury,” Pl.’s Objs., ECF No. 26 at 28; but rather whether FSS’ procurement of the Diplomatic Note caused Ms. Han an injury. Ms. Han is unable to establish such an injury absent excessive conjecture far removed from the boundaries of this Court’s purview.
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Section 13-423(a) provides specific personal jurisdiction based on enumerated connections between a claim, the defendant, and the District of Columbia.

Hooli v. Combs · filed 2024-11-20(a)

In any event, the District of Columbia’s long-arm statute, D.C. Code § 13-423, provides no basis for the exercise of jurisdiction over defendant Mitcham in this case.
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Section 13-423 permits personal jurisdiction when claims arise from a defendant’s business transactions in the District or from tortious injury caused there by an act there.

Smartmatic USA Corp. v. Herring Networks, Inc. · filed 2022-06-21(a)(1), (a)(3)

The Court possesses personal jurisdiction over OAN under § 13-423(a)(1) of the District’s long-arm statute. ... The Court also has personal jurisdiction over OAN under § 13-423(a)(3) of the District’s long-arm statute because OAN “caus[ed] tortious injury in the District of Columbia by an act or omission in the District of Columbia.” D.C. Code § 13-423(a)(3).
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Section 13-423(a) does not support specific jurisdiction when the complaint alleges no claims arising from a defendant’s District contacts and no injury in the District.

Pizarro v. Mead · filed 2022-08-25(a)

Accordingly, Mr. Pizarro has not alleged that he suffered an injury within the District of Columbia and that would comport with long-arm jurisdiction. See D.C. Code Ann. § 13-423(a).
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Section 13-423(a) permits specific jurisdiction only when a claim arises from qualifying contacts with the District or tortious injury there.

Baptichon v. U.S. Department of Education · filed 2023-03-17(a)

Baptichon has not shown that the long-arm statute supplies a basis for specific jurisdiction.
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Section 13-423 permits specific personal jurisdiction only when the claim arises from a defendant’s qualifying connection to the District of Columbia; alleged conduct with no District connection does not suffice.

Martin v. United States · filed 2025-01-27

He does not, for example, allege that Bravenec and Torralba Properties have conducted any business in the District, committed any torts in the District, or are linked to the District in any way. See D.C. Code § 13-423.
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Section 13-423 requires facts connecting the defendant’s conduct or the alleged injury to the District before a court may exercise specific personal jurisdiction under these provisions.

Riggs v. Eighteenth Judicial District Court · filed 2022-10-04(a)(1), (3), (4)

Because Riggs’s Amended Complaint lacks any factual allegations tying St. Francis to the District of Columbia, the District’s long-arm statute does not allow the Court to exercise personal jurisdiction over St. Francis.
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Section 13-423(a)(1) requires business related to the suit in the District, while section 13-423(a)(4) requires regular business, persistent conduct, or substantial revenue there when an out-of-District act causes injury in the District.

Changing the World Films, LLC v. Parker · filed 2022-12-02(a)(1), (a)(4)

The plaintiffs cannot establish that this Court has personal jurisdiction over the Film Defendants under § 13-423(a)(1) because none of the defendants transacted relevant business in the District. ... Section 13-423(a)(4) of the District’s long-arm statute also does not apply to the Film Defendants. The plaintiffs have not established the requisite “plus factor,” namely that the Film Defendants regularly do business, engage in a persistent course of conduct, or derive substantial revenue from the District.
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Section 13-423(a) requires a listed contact with the District of Columbia to establish specific jurisdiction over a nonresident defendant.

Watts v. U.S. Department of Justice Office of the Inspector General · filed 2022-12-09(a)

To show specific jurisdiction, a plaintiff must meet the requirements of the Due Process Clause and that jurisdiction’s long-arm statute. D.C.’s long-arm statute enumerates the kinds of contacts with the District that are sufficient to bring a non-resident defendant into a D.C. court: ... D.C. Code § 13-423(a) (2012). ... Plaintiffs make no allegation in their Complaint or Opposition that any of these Defendants had any contacts — either related to this claim or otherwise — with the District of Columbia.
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Section 13-423 requires contacts with the District of Columbia sufficient to support specific personal jurisdiction.

Baptichon v. EDUC · filed 2024-01-11(a)-(b)

Appellant has failed to establish any contacts with the District of Columbia that would support the district court’s exercise of either general or specific jurisdiction over Cooley. See id. (construing D.C. Code. § 13-334 and § 13-422); D.C. Code § 13-423(a)-(b); Livnat v. Palestinian Auth., 851 F.3d 45, 57 (D.C. Cir. 2017) (holding that “[c]onclusory statements” do not satisfy the plaintiff’s burden of showing pertinent jurisdictional facts to survive a motion to dismiss for lack of personal jurisdiction (quotation omitted)).
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Section 13-423 requires sufficient contacts with the District of Columbia to support personal jurisdiction.

Visconti v. Burghardt · filed 2024-07-23

Moreover, neither Judge Burghardt nor the Superior Court of Los Angeles is “essentially at home” in the District of Columbia, Ford Motor Co. v. Mont. Eighth Jud. Dist. Ct., 592 U.S. 351, 358 (2021), and neither appears to have the type of contacts with the District of Columbia that would satisfy the D.C. long-arm statute, D.C. Code § 13-423, or the constitutional requirements of due process, GTE New Media Servs. Inc. v. BellSouth Corp., 199 F.3d 1343, 1347 (D.C. Cir. 2000).
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Section 13-423(a)(1) requires a claim arising from business transacted in the District; subsection (a)(4) requires an out-of-District act causing injury in the District plus regular business, persistent conduct, or substantial revenue there.

Dbw Partners, LLC v. Market Securities, L.L.C. · filed 2024-08-10(a)(1), (a)(4)

Plaintiff has failed to demonstrate, however, that personal jurisdiction may be exercised over BTG, under District of Columbia’s long-arm statute, D.C. Code § 13-423(a)(1) and (a)(4), and, accordingly, BTG’s motion to dismiss the single claim against it in Count III is granted.
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Section 13-423(a) requires the defendant’s own District business contacts or a tortious injury connected to its conduct in or outside the District to support specific jurisdiction.

Madaket LLC v. Sweet Grace Distilling Company LLC · filed 2024-10-31(a)(1), (a)(3), (a)(4)

The Court is not permitted to exercise personal jurisdiction over Reyes here because Defendant has transacted no business in — and thus did not have sufficient contacts with — the District. As a non-resident holding company without a license to sell alcohol, Reyes does not distribute Surfside canned cocktails anywhere, let alone here in the District. In addition, Plaintiff has not provided facts in either its Amended Complaint or its Opposition to show how the alleged tortious injury is directly connected to Defendant’s conduct in or out of the District.
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Section 13-423(a)(1)–(6) permits specific jurisdiction only when the claim arises from the defendant’s listed conduct in the District of Columbia.

Gold v. Global Aerospace Underwriting Managers, Ltd. · filed 2025-06-03(a)(1)–(6)

Gold’s claim for relief therefore does not “aris[e]” from Global’s acts in the District of Columbia, including “transacting any business,” “contracting to supply services,” “causing tortious injury,” “having an interest in, using, or possessing real property,” or “contracting to insure or act as surety for or on any person, property, or risk, contract, obligation, or agreement.”
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Section 13-423(a)(1) and (4) requires relevant conduct connecting the defendant to the District to support specific jurisdiction.

Cheeks v. Powerball · filed 2025-06-06(a)(1), (a)(4)

Cheeks has similarly failed to establish that this Court maintains specific jurisdiction over the Florida Lottery because he alleges no relevant contacts between the Florida Lottery and the District of Columbia that would support an exercise of jurisdiction. As relevant here, the District of Columbia’s long-arm statute extends to “a claim for relief arising from the [defendant’s] transacting any business in the District of Columbia;” or the defendant’s “causing tortious injury in the District of Columbia by an act or omission outside the District of Columbia if he regularly does or solicits business, engages in any other persistent course of conduct, or derives substantial revenue from goods used or consumed, or services rendered, in the District of Columbia.” D.C. Code § 13-423(a)(1), (4).
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Section 13-423 permits personal jurisdiction over a nonresident only when the claim arises from one of the listed connections to the District of Columbia.

Gu v. Trump · filed 2025-12-19

The acts alleged in Ms. Gu’s Complaint do not fall under any of these bases of jurisdiction. The Complaint alleges that the initial incident was in a New York apartment building, resulting in a report to police by Mr. Chen in New York.
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Section 13-423 does not provide specific personal jurisdiction when the defendants’ alleged conduct occurred in New York and the plaintiffs show no resulting injury in the District of Columbia.

Zhang v. Hotel Fortune · filed 2025-10-07

All the alleged conduct occurred in New York, and Plaintiffs offer no theory of how Defendants’ alleged actions caused them injury in the District of Columbia. ... The court therefore lacks both general jurisdiction and specific jurisdiction under the D.C. long-arm statute, D.C. Code § 13-423.
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Section 13-423(a)(1)-(3) does not confer specific personal jurisdiction merely because defendants used interstate mail and wires to injure plaintiffs; the alleged conduct must connect them to the District of Columbia.

Pinkerton v. Reinhardt · filed 2026-06-24(a)(1)-(3)

Plaintiffs’ allegations of the defendants’ use of interstate mail and wires to injure plaintiffs are insufficient to show that the defendants have “transact[ed] any business,” “contract[ed] to supply services,” or “caus[ed]tortious injury in the District of Columbia.” Compl. at ¶ 13; see D.C. Code § 13-423(a)(1)-(3) (emphasis added).
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Jurisdictional discovery

A plaintiff with a good faith basis to believe discovery will show that a defendant transacted business in the District may obtain jurisdictional discovery under § 13-423(a)(1).

Delta Sigma Theta Sorority, Inc. v. Bivins · filed 2013-10-21(a)(1)

Consequently, the plaintiff has “at least a good faith belief that [jurisdictional] discovery will enable it to show that the court hás personal jurisdiction over the defendant,” FC Inv. Grp. LC v. IFX Markets, Ltd., 529 F.3d 1087, 1093-94 (D.C. Cir. 2008), since further discovery could show that the defendants are “transacting any business in the District of Columbia” as required by the District of Columbia’s long-arm statute, which governs jurisdictional issues in this case. D.C. Code § 13-423(a)(1); see also FC Inv. Grp LC, 529 F.3d at 1094-95 (“A plaintiff seeking to establish specific jurisdiction over a nonresident defendant must establish that specific jurisdiction comports with the forum’s long-arm statute.”).
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Marital relationships

Section 13-423(a)(7)(E) permits personal jurisdiction over a claim arising from a marital relationship in the District when exercising jurisdiction is consistent with due process.

SPELLMAN v. JOSEPH BOLAND, PERSONAL REPRESENTATIVE OF THE ESTATE OF MICHAEL JOSEPH KELLY · filed 2016-07-07(a)(7)(E)

Accordingly, we conclude that the Superior Court had personal jurisdiction over Mr. Boland under D.C. Code § 13-423 (a)(7)(E).
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Section 13-423(a)(7)(E) permits personal jurisdiction over a claim arising from a marital relationship in the District when exercising jurisdiction satisfies due process.

Spellman v. Boland · filed 2016-07-07(a)(7)(E)

Accordingly, we conclude that the Superior Court had personal jurisdiction over Mr. Boland under D.C.Code § 13-423(a)(7)(E).
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Notes 451–490 of 490, oldest cases first.

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