223A Mass. Gen. Laws § 3

Section 3(a) does not confer personal jurisdiction over an out-of-state buyer based on isolated purchases and limited communications with a Massachusetts seller when the buyer has no other business contacts with the state.

Rolivia, Inc. v. Emporium Nostrum, Inc. · filed 2013-11-08(a)

Either way, the wine was sold by Rolivia from Massachusetts, but that alone, together with other uncontroverted facts, does not give rise to personal jurisdiction.

Section 3(a) reaches a nonresident purchaser that repeatedly orders substantial inventory from a Massachusetts supplier, even without physical presence in the Commonwealth.

Diamond Group, Inc. v. Selective Distribution International, Inc. · filed 2013-11-25(a)

However, no formal or principled distinction separates purchasers from vendors under the statute. The controlling standard is the neutral test of “transacting any business.” The purchase of necessary inventory is the transaction of such business.

Section 3(a) permits personal jurisdiction when a person transacts business in Massachusetts and the claim arises from those transactions; at the pleading stage, a prima facie showing suffices.

Donaldson v. Shapemix Music, LLC · filed 2013-12-11(a)

The defendants’ assessment and subsequent misrepresentation of Shapemix’s funding contributed to the plaintiffs’ injuries. Therefore, at this stage, the plaintiff has alleged sufficient facts to satisfy the longarm statute.

Section 3(a) permits personal jurisdiction over a nonresident corporate officer whose repeated business contacts with a Massachusetts resident give rise to the suit, even when the officer acted for the corporation.

Luo v. Tao Ceramics Corp. · filed 2014-04-10(a)

If believed, this allegation alone is enough to satisfy the “transacted] any business” requirement of the Massachusetts Longarm statute authorizing jurisdiction over Ms. Qian.

Section 3(a) permits personal jurisdiction when a defendant transacts business in Massachusetts and the plaintiff’s claims arise from that business.

Boston Pads, LLC v. Black Dog Group, Inc. · filed 2015-04-21(a)

For reasons explained below, this court accepts that personal jurisdiction over TBDGI is properly constituted under G.L.c. 223A, §3(a). ... Because Boston Pads’ claims are based on, or relate directly to, the Contract and TBDGI’s representations relating thereto, this court finds that Boston Pads’ claims against TBDGI did “arise from” the latter’s transaction of business in Massachusetts.

Section 3(a) does not require a defendant to have successfully solicited business in Massachusetts to qualify as transacting business there.

Cossart v. United Excel Corporation · filed 2015-09-30(a)

But Tatro does not hold that the "transacting business" language of Section 3(a) requires that a defendant have successfully solicited business in Massachusetts.

Section 3(a) permits personal jurisdiction when a defendant transacts business in Massachusetts and the claim arises from that transaction; physical presence is unnecessary.

Alere, Inc. v. Wallace · filed 2015-10-07(a)

Consequently, I find that Wallace and Stocksdale transacted business in the Commonwealth by the sale of their company. ... Accordingly, Alere satisfies its burden of showing that personal jurisdiction may be maintained for claims against Wallace and Stocksdale under the Massachusetts longarm statute.

Section 3(a) permits personal jurisdiction when a defendant transacts business in Massachusetts and the claim arises from that business; purposeful work communications can satisfy these requirements.

Crane & Co. v. Jordan · filed 2016-09-01(a)

In order for jurisdiction to exist under Section 3(a), the facts must satisfy two requirements: (1) the defendant must have transacted business in Massachusetts; and (2) the plaintiffs claim must have arisen from the transaction of business by the defendant. ... Clearly, these contacts were purposeful, and not few in number. ... That the Crane employees in Massachusetts were of only limited assistance to him in this work and that the communications did not directly bear on the technology that is the subject of the patent application does not change this Court’s conclusion that this action “arose from” Jordan’s contacts with this state and those contacts are sufficient to permit the assertion of personal jurisdiction.

Section 3(a) permits personal jurisdiction when a defendant solicits Massachusetts business through a website directing residents to local retailers and the claim arises from that business.

LaFond v. Salomon North America, Inc. · filed 2011-12-20(a)

Because this court finds that jurisdiction is appropriate under G.L.c. 223A, §3(a), it will not address the other provisions. ... Rather, it explicitly solicits business from Massachusetts residents by directing them to Massachusetts’ retailers that sell Salomon products. ... Further, LaFond’s claims against Salomon S.A. arise out of this business where he stated in an affidavit that he purchased the binding at issue in part based on research he conducted on the Website.

Section 3(a) allows personal jurisdiction over a corporate officer based on the officer’s own Massachusetts contacts, even when made in a corporate role.

Rissman Hendricks & Oliverio, LLP v. MIV Therapeutics Inc. · filed 2012-09-28(a)

No Massachusetts court has adopted the fiduciary shield doctrine, and courts in the First Circuit do not recognize the doctrine as a limitation on the Massachusetts long-arm statute.

Section 3(a) does not confer jurisdiction based on an untargeted website and isolated transactions, and § 3(d) requires a persistent course of conduct or substantial revenue in Massachusetts.

Sun Life Assurance Co. v. Sun Bancorp, Inc. · filed 2012-10-04(a), (d)

Plaintiffs here have not alleged facts that would meet that standard, and thus subsection (a) of the long-arm statute cannot provide the basis for personal jurisdiction here. ... Thus, plaintiffs have not met their burden, under subsection (d), of showing that defendants either engaged in a “persistent course of conduct” related to business in Massachusetts or that they derived “substantial revenue” from customers who reside in Massachusetts.

Section 3(a) permits personal jurisdiction when a defendant transacts business in Massachusetts and the plaintiff’s claim arises from that business; on a motion decided from affidavits, the plaintiff must make a prima facie showing.

American Paper Recycling, Inc. v. Renew Bahamas, Ltd. · filed 2016-09-23(a)

This Court concludes that American has made a prima facie case that Renew transacted business in Massachusetts within the meaning of G.L.c. 223A, §3(a).

Section 3(a) permits personal jurisdiction when a company retains sufficient control over the marketing of its products by local franchisees.

In re Civil Investigative Demand No. 2016-EPD-36 · filed 2017-01-11(a)

The quantum of control Exxon retains over its BFA Holders and the BFA Holders’ franchisees as to marketing means that Exxon retains sufficient control over the entities actually marketing and selling fossil fuel derived products to consumers in the Commonwealth such that the court may assert personal jurisdiction over Exxon under G.L.c. 223A, §3(a).

Section 3(a) permits personal jurisdiction when a defendant transacts business in Massachusetts and the plaintiff’s injury arises from that business, including denial of access to a commercial website.

Access Now, Inc. v. Otter Products, LLC · filed 2017-12-04(a)

Because the harm — the denial of access to the website — occurred in the Commonwealth, the injury arises from Otter’s transaction of business via its website in the Commonwealth. ... Therefore, this prong is met and jurisdiction can be found under Mass. Gen. Laws ch. 223A, § 3(a).

Section 3(a) permits personal jurisdiction when a defendant transacts business in Massachusetts and the plaintiff’s claim arises from that business, including an injury from an inaccessible website used for sales in the state.

Access Now, Inc. v. Sportswear, Inc. · filed 2018-03-22(a)

Having found that Sportswear transacts business in the forum, within the meaning of the Massachusetts long-arm statute, the Court must next determine whether the claim "arises from" that activity. ... Because Théberge's denial of access to Sportswear's website occurred in the forum, the injury arises from Sportswear's transaction of business through its website in Massachusetts.

Section 3(a) permits personal jurisdiction when a nonresident transacts business in Massachusetts and the matter arises from that business.

Exxon Mobil Corp. v. Attorney General · filed 2018-04-13(a)

This network represents Exxon's "purposeful and successful solicitation of business from residents of the Commonwealth," Tatro, 416 Mass. at 767, such that it satisfies the "transacting any business" prong of § 3 (a). ... This leads to our conclusion that the C.I.D. "aris[es] from" the BFA and Exxon's network of branded fuel stations in Massachusetts.

Section 3(a) permits personal jurisdiction when a defendant transacts business in Massachusetts and the plaintiff’s claim arises from that business.

Roy v. FedEx Ground Package Systems, Inc. · filed 2018-05-22(a)

Thus, the court finds that its exercise of personal jurisdiction over FedEx Ground with respect to Roy’s and Trumbull’s claims is authorized by section 3(a) of the Massachusetts long-arm statute. However, Plaintiffs have not met the requirements for long-arm jurisdiction over FedEx Ground under section 3(a) with respect to Sullivan-Blake’s claim.

Section 3(a) permits personal jurisdiction when a defendant transacts business in Massachusetts and the claim arises from that business.

Geis v. Nestlé Waters N. Am., Inc. · filed 2018-07-02(a)

Geis's complaint alleges facts that easily satisfy the long-arm statute's requirements. ... The allegations in the complaint make it clear that, but for NWNA's call center in Massachusetts and the one-year agreements the company negotiated from that call center, Geis would not have suffered an injury from the alleged breach of contract, fraud, or deceptive practices.

Section 3(a) permits personal jurisdiction when a defendant transacts business in Massachusetts and the claim arises from that business.

Lyndon v. Nestle Waters North America, Inc. · filed 2018-07-02(a)

These allegations -- particularly the number of Massachusetts representatives employed by NWNA -- demonstrate that the company participated in economic life in the Commonwealth.

Section 3(a) permits personal jurisdiction when a defendant transacts business in Massachusetts and the claim arises from those transactions.

QLS Logistic Services, LLC v. JAWS Associates, LLC · filed 2018-11-06(a)

Here, considering “the relations between the parties, their respective activities under the contract, and the linkages ... between the defendant’s participation in the transaction and Commonwealth of Massachusetts,” the Court finds that Defendants Carson, Williams, and Moore have transacted business in Massachusetts and Plaintiff’s claims have arisen from those transactions.

Section 3(a) permits personal jurisdiction when a defendant transacts business in Massachusetts and the plaintiff's claims arise from that business under a but-for causation standard.

Ouellette v. True Penny People, LLC · filed 2018-11-29(a)

Because Defendant has transacted business in the Commonwealth within the meaning of the Massachusetts long-arm statute and because Plaintiff's claims arise from that transaction under the "but for" standard, I find that asserting jurisdiction is proper under state law.

Section 3(a) covers business transactions in Massachusetts, including a contract partly negotiated and signed there, when the claim arises from those transactions.

Targetsmart Holdings, LLC v. Ghp Advisors, LLC · filed 2019-02-06(a)

Since the Letter Agreement is governed by the laws of Massachusetts, [Dkt. No. 39-1, Letter Agreement at p. 6, § 15] and was at least partly negotiated and signed in Massachusetts, it evidences Catalist’s intent to “participate in the commonwealth’s economic life,” United Electrical, 960 F.2d 1087, and is sufficient to constitute business transactions in the Commonwealth within the scope of the long-arm statute.

Section 3(a) does not treat an isolated call from New York agreeing to manage New York property as transacting business in Massachusetts.

Packs v. Bartle · filed 2019-03-06(a)

Standing alone, that phone call is insufficient to establish that Davidson was transacting business in the Commonwealth under Section 3(a).

Section 3(a)’s business transaction requirement can cover a loan agreement even when the loan serves a nonprofit purpose.

Woods Hole Oceanographic Institution v. ATS Specialized, Inc. · filed 2019-03-20(a)

Here the Court finds that the loan agreement between the Museum and Woods Hole Oceanographic Institution (“WHOI” or “plaintiff”), even if related to a nonprofit purpose, is a business transaction within the purview of the long-arm statute for the same reasons the conduct was determined to be commercial under the FSIA.

Section 3(a) permits personal jurisdiction when hotel advertisements sent into Massachusetts are a but-for cause of the plaintiff’s injury.

Nandjou v. Marriott International Inc. · filed 2019-04-29(a)

Because the advertisements sent to Massachusetts are a but-for cause of the injury, the long-arm statute is satisfied.

Section 3(a) permits personal jurisdiction when claims arise from a defendant’s transaction of business in Massachusetts, including the solicitation of services to be performed there.

Conning v. Halpern · filed 2019-06-18(a)

Because the Court concludes that Conning’s claims arise from the Defendants transacting business in the Commonwealth within the meaning of subsection 3(a) of the Massachusetts long-arm statute, it need not address Conning’s assertion that Defendants’ conduct also comes within subsections (b) and (d) of the long-arm statute.

Section 3(a) permits personal jurisdiction when a defendant’s business contacts in Massachusetts are a but-for cause of the plaintiff’s injury.

Nandjou v. Marriott International Inc. · filed 2019-07-08(a)

Because the advertisements sent to Massachusetts are a but-for cause of the injury, the long-arm statute is satisfied.

Section 3(a) requires a Massachusetts business transaction to be a but-for cause of the claimed harm; the plaintiff must allege facts connecting the transaction to Massachusetts.

Goodell v. Bayer HealthCare Pharmaceuticals Inc. · filed 2019-09-30(a)

Section 3(a), for example, provides jurisdiction over companies “transacting any business in this commonwealth.” Mass. Gen. Laws ch. 223A, § 3(a). This section has been consistently interpreted to require that the transactions occurring in this state were a “but for” cause of the harm alleged in the claim. ... Plaintiff’s failure to allege facts relating to this transaction makes any further analysis of the Massachusetts long-arm statute and constitutional analysis premature.

Section 3(a) requires the claim to arise from business the defendant transacted in Massachusetts; accessing a generally available website there does not establish jurisdiction.

Bean v. Johnson & Wales University · filed 2019-10-08(a)

Just because plaintiff accessed a generally available website from Massachusetts does not subject JWU to the long-arm statute.

Section 3(a) permits personal jurisdiction when a defendant attempts to transact business in Massachusetts and that business is a but-for cause of the claim.

King v. Prodea Systems, Inc. · filed 2019-12-20(a)

The satisfaction of the second requirement of section 3(a) with respect to the Corporate Defendants is uncontroversial. The “but-for” standard is met where, as here, the plaintiff’s claims relate to work performed in Massachusetts pursuant to an employment contract.

Section 3(a) requires the defendant to have attempted to participate in Massachusetts’s economic life and that business activity to have been a but-for cause of the alleged harm.

Perras v. Trane U.S., Inc. · filed 2020-05-20(a)

This requires the plaintiff to show that 1) the defendant attempted to participate in the Commonwealth’s economic life and 2) the transacted business was a “but for” cause of the alleged harm.

Section 3(a) permits jurisdiction when recruiting, contracting with, and training a driver in Massachusetts are business transactions that cause the claimed injury under a but-for test.

Moura v. New Prime, Inc. · filed 2018-10-09(a)

I find, however, that contacting, contracting with, and training Mr. Moura was part of New Prime’s transaction of business in the Commonwealth. Further, it is clear that but for this transaction, Plaintiff would not have been harmed. Indeed, it was the first step in the train of events that led to his death. Therefore, I find that asserting jurisdiction is proper under the Massachusetts long-arm statute.

Section 3(a) allows an agent's Massachusetts business activity to support jurisdiction over the principal when the plaintiff's claim arises from that activity.

Von SCHönau-Riedweg v. Rothschild Bank AG · filed 2019-06-17(a)

It follows that, if von Plotho was Rothschild's agent, von Schönau made out a prima facie case that her 2004 $ 10 million investment in CET arose from Rothschild's transaction of business in Massachusetts.

Section 3(a) requires a claim to arise from the defendant’s Massachusetts business activities; unrelated business in the state does not establish personal jurisdiction.

Harness v. AngioDynamics, Inc. · filed 2021-09-28(a)

Nevertheless, personal jurisdiction is not proper under § 3(a) because Mr. Harness’ claims do not arise from Defendants’ business in Massachusetts.

Section 3(a) does not treat a law firm as transacting business in Massachusetts merely because it represents an out-of-state client in an out-of-state proceeding against a Massachusetts resident.

Restuccia v. H&R Block Tax Services LLC · filed 2021-10-07(a)

None of the cases that Mr. Restuccia cites, see [ECF No. 16 at 7–8], suggest that a law firm transacts business in Massachusetts within the meaning of § 3(a) merely by representing a non-Massachusetts client in an adversarial legal proceeding, in a non-Massachusetts forum, even if the opposing party and counsel are Massachusetts residents, and the Court is unwilling to read § 3(a) so broadly in the absence of on-point authority.

Section 3(a) requires a plaintiff to link the claim to the defendant’s business activities in Massachusetts.

Lopez v. AngioDynamics, Inc. · filed 2021-10-28(a)

Against this backdrop, Mr. Lopez has failed to show the required link between his claims and Defendants’ Massachusetts contacts. Accordingly, the Court does not have jurisdiction over Defendants under the Massachusetts long-arm statute.

Section 3(a) permits personal jurisdiction when a defendant deliberately transacts business in Massachusetts and that business is a but-for cause of the claimed harm; a jointly chosen Massachusetts escrow agent and account can satisfy that standard.

Stag Williamsport, LLC v. BHN ASSOCIATES, LLC · filed 2022-07-07(a)

Most important in that determination is the purposeful designation of an escrow agent and the establishment of an escrow account in the Commonwealth to facilitate the contract at issue. ... As a result, plaintiff has identified sufficient contacts of BHN with Massachusetts to satisfy the long-arm statute.

Section 3(a) requires facts showing purposeful business activity in Massachusetts; conclusory allegations of advertising and routine business do not suffice.

Power v. Connectweb Technologies, Inc. · filed 2023-01-04(a)

While Power alleges generally that J.P. Cooke “regularly and routinely does business in Massachusetts” and “actively advertises products specifically targeting Massachusetts customers” (Am. Compl. ¶ 19), such conclusory allegations are inadequate to establish that J.P. Cooke acted with a purposeful intent to transact business in the Commonwealth.

Section 3(a) permits jurisdiction over a claim when the defendant’s business contacts in Massachusetts are a but-for cause of that claim.

Connell Limited Partnership v. Associated Indemnity Corporation · filed 2023-01-06(a)

However, the outcome differs with respect to Connell’s statutory claim where Defendants’ correspondence with and representations to Connell in Massachusetts are the “but for” cause of Connell’s claim that Defendants violated M.G.L. c. 176D. Accordingly, the court finds jurisdiction exists under Massachusetts long-arm statute based on Connell’s statutory claim.

Section 3(a) is satisfied when a defendant transacts business in Massachusetts and that business is a but for cause of the plaintiff’s alleged harm.

Sonate Corporation v. Dunkin' Brands Group, Inc. · filed 2023-03-24(a)

Contrary to Plaintiff’s assertions that these contacts were simply a result of Dunkin’s location, the facts demonstrate not only that Beyond “attempted to participate in [Massachusetts’s] economic life” sufficient to meet the “transacting any business” requirement of the state’s long-arm statute, but also that the transacted business was a but for cause of Plaintiff’s alleged harm.

Section 3(a) requires a defendant to transact business in Massachusetts and the claim to arise from that business; CureVac’s communications and unrelated research agreements did not satisfy those requirements.

SE v. AG · filed 2023-05-16(a)

The purported activity is insufficient to afford jurisdiction under the Massachusetts long-arm statute.

Section 3(a) permits personal jurisdiction when a nonresident transacts business in Massachusetts and the plaintiff’s claim arises from that business under a but-for causation test.

Doucet v. FCA US LLC · filed 2023-06-08(a)

Consistent with our broad construction of G. L. c. 223A, § 3 (a), see id. at 767, we conclude that Doucet's claims arose from FCA US's transaction of business in the Commonwealth, in satisfaction of our long-arm statute.

Section 3(a) does not authorize personal jurisdiction when a defendant’s Massachusetts contacts are incidental to a contemplated contract for an out-of-state sale.

Reagent Fund II, LP v. Lotus Gunworks of South Florida, LLC · filed 2023-08-15(a)

Since the Defendants’ contacts in Massachusetts are more aptly characterized as incidental rather than instrumental to the parties contemplated contract, their contacts cannot meet the requirements of Section 3A.

Section 3(a) requires a claim to arise from the defendant’s business contacts in Massachusetts; unrelated contacts do not support personal jurisdiction.

Frawley v. Nexstar Media Group, Inc. · filed 2023-09-18(a)

Section 3(a) does not apply here to Nexstar’s actions because Nexstar’s contacts in Massachusetts are not related to the controversy here and they played no role in the “train of events” that resulted in the alleged injury.

Section 3(a)'s transacting-business requirement is not satisfied merely because a company's untargeted global advertising reaches a Massachusetts resident.

Sheldon v. AG · filed 2023-09-22(a)

Without evidence that DT Swiss has targeted Massachusetts with more intent and specificity than global trade magazines and online trade editorials, the fact that those marketing efforts reached Sheldon in Massachusetts is insufficient to satisfy the transacting business requirement of the long-arm statute.

Section 3(a) does not give a court personal jurisdiction over a corporate officer based solely on the corporation’s Massachusetts business; the officer’s own role in that business matters.

Katz v. Liberty Power Corp., LLC · filed 2023-09-22(a)

There are no allegations in the proposed TAC suggesting that Hernandez was a “primary participant” in any business Holdings or Corp transacted in Massachusetts, so this subsection does not apply.

Section 3 permits personal jurisdiction over an out-of-state employer that transacts business in Massachusetts when an employee’s claim arises from that business.

Tisbert v. New England Mobile Crushing Services, Inc. · filed 2024-03-22

Here, the Massachusetts long-arm statute applied to NEMCS because it "transact[ed] . . . business in this [C]ommonwealth," G. L. c. 223A, § 3, and Tisbert's "claim . . . [arose] from the transaction of business."

Section 3(a) permits personal jurisdiction based on business transacted in Massachusetts, but jurisdiction over a corporate officer requires an independent basis tied to that officer’s own conduct.

Smith v. Aphex BioCleanse Systems, Inc. · filed 2024-04-10(a)

However, under the Massachusetts long-arm statute, jurisdiction over a corporate officer cannot be based solely on jurisdiction over the corporation itself. ... Accordingly, this court finds that the facts and evidence proffered by Smith as to Olund’s individual actions in connection with his employment satisfy the long-arm statute.

Section 3(a) requires a connection between the defendant’s Massachusetts business contacts and the plaintiff’s claims; communications with Massachusetts employees do not establish jurisdiction without that connection.

Advent Technologies, Inc. v. Kaye · filed 2024-04-29(a)

This evidence is insufficient to tie either Kaye or Chen’s contacts with Massachusetts to Advent Inc.’s claims against them, including that either Defendant acquired the specific pictures or documents they allegedly misappropriated via their communications with Massachusetts-based personnel.

Section 3(a) does not permit personal jurisdiction based on minor, incidental contacts with a Massachusetts resident when the defendant's business is directed at another State.

SARVIS v. LESLIE M. BASSETT & Another. · filed 2024-11-04(a)

Accordingly, Sarvis failed to demonstrate that G. L. c. 223A, § 3 (a), was satisfied.

Section 3(a)'s transacting-business requirement is met when an insurance broker's call and proposals to Massachusetts residents give rise to their claims.

Bain v. McGriff Insurance Services, LLC · filed 2025-03-25(a)

Thus, the “transacting any business” requirement of § 3(a) has been met.

Section 3(a) requires a claim to arise from the defendant’s Massachusetts business transactions; unrelated business contacts do not establish personal jurisdiction.

Jane Doe 1 v. Jetblue Airways Corporation · filed 2021-08-03(a)

Even though Plaintiffs allege that Johnson and Watson participated in JetBlue’s investigation of Plaintiffs’ complaints in Massachusetts, Johnson and Watsons’s participation in that investigation is not a “but for” cause of any of the claims that Plaintiffs assert against them. Therefore, personal jurisdiction is not proper under § 3(a).

Section 3(a) requires a claim to arise from the defendant’s Massachusetts business transactions; conducting business in Massachusetts alone is insufficient.

Pettit v. AngioDynamics, Inc. · filed 2021-09-28(a)

As to the second clause, Ms. Pettit’s claims do not arise from Defendants’ business transactions in Massachusetts. ... Accordingly, the Court does not have jurisdiction over Defendants pursuant to the Massachusetts long-arm statute.

Section 3(a) requires a plaintiff’s claim to arise from the defendant’s business activities in Massachusetts.

Mora v. AngioDynamics, Inc. · filed 2021-10-28(a)

Against this backdrop, Ms. Mora has failed to show the required link between her claims and Defendants’ Massachusetts contacts. Accordingly, the Court does not have jurisdiction over Defendants under the Massachusetts long-arm statute.

Section 3(a) requires a claim to arise from the defendant’s Massachusetts business transactions for personal jurisdiction to attach.

Walters v. AngioDynamics, Inc. · filed 2021-10-28(a)

Against this backdrop, Mr. Walters has failed to show the required link between his claims and Defendants’ Massachusetts contacts. Accordingly, the Court does not have jurisdiction over Defendants pursuant to the Massachusetts long-arm statute.

Section 3 requires a plaintiff’s claims to arise from the defendant’s Massachusetts contacts; the insurers’ alleged conduct concerning a New Jersey project did not meet that requirement.

Windover Construction, Inc. v. Selective Insurance Company of America · filed 2022-12-08

But the Massachusetts long-arm statute, like the demands of constitutional due process, requires at base that a plaintiff’s claims “aris[e] from” defendant’s contacts with the state. ... Windover has not shown that its claims “arise from” any conduct of Merchants and Selective in Massachusetts.

Section 3(a) requires a plaintiff’s claim to arise from the defendant’s Massachusetts business transactions; transactions that are not a but-for cause of the alleged injury do not support personal jurisdiction.

Mexicanos v. Smith & Wesson Brands, Inc. · filed 2024-08-07(a)

Without any such connection, there is no basis to assert personal jurisdiction under the Massachusetts long-arm statute, because none of the transactions with Massachusetts is alleged to be a but-for cause of any of plaintiff’s injuries.

Section 3(a) does not provide personal jurisdiction when the plaintiff’s claims do not arise from the defendant’s activities in Massachusetts.

Keane v. Expeditors International of Washington, Inc. · filed 2024-08-22(a)

Keane has not met his burden under Section 3(a) of the Massachusetts long-arm statute because his causes of action do not arise from Expeditors HK’s activities in Massachusetts.

Section 3(a) and (d) do not permit personal jurisdiction when the allegations show neither an attempt to participate in Massachusetts’s economic life nor regular business, persistent conduct, or substantial revenue there.

Lewis v. Hill · filed 2023-07-24(a), (d)

Jurisdiction is not permitted under the Massachusetts Long-Arm Statute, because Mr. Lewis’s allegations do not show that the defendants “attempted to participate in the commonwealth’s economic life,” Cossart, 804 F.3d at 18, and likewise the allegations do not show that either defendant “regularly does or solicits business, or engages in any other persistent course of conduct, or derives substantial revenue from goods used or consumed or services rendered” in Massachusetts.

Section 3(a) permits personal jurisdiction only when the defendant transacted business in Massachusetts and the claim arose from that business.

Azumi LLC v. Lott & Fischer, PL · filed 2022-08-16(a)

In any event, even if those connections were sufficient to constitute the transaction of business in Massachusetts, jurisdiction would not lie because the claims here at issue do not arise from the alleged in-forum activity.

Section 3(a) permits personal jurisdiction over a defendant for claims arising from its business transactions in Massachusetts.

Moshe Yanai, Rachel Yanai, and Michal International Investment LLC v. Zack Keinan, Individually and as General Partner o · filed 2025-04-08(a)

The Massachusetts long-arm statute authorizes specific jurisdiction as to a cause of action arising from the transaction of business in Massachusetts by the defendant or its agent. See G.L. c. 223A, § 3(a). ... In other words, the claims relevant to the preliminary injunction motion arise from the Fund’s transaction of business in Massachusetts.

Section 3(a) permits personal jurisdiction when a defendant transacts business in Massachusetts and the claim arises from that business; employing a worker in the state through a joint venture can qualify.

McCloskey v. PredictiveGenies, Inc. · filed 2025-04-25(a)

The “transacting any business” portion of the statute should be construed broadly—such that employing a person in the state would fall within a broad construction of this language. ... Furthermore, the corporate Defendants jointly recruited McCloskey, employed her, and advertised Hiring Cube in Massachusetts. ... Accordingly, the Court finds that the exercise of personal jurisdiction over the Defendants is proper under the long-arm statute.

Section 3(a) permits personal jurisdiction when a defendant transacts business in Massachusetts and that business is causally related to the plaintiff’s alleged injury.

Aquidneck Trucking, LLC v. Lightspeed Trucking, LLC · filed 2025-07-03(a)

Beacon “transact[ed] [] business” in the Commonwealth by its frequent communications with Plaintiffs, who were in Massachusetts, to bring about the Lightspeed sale. ... Accordingly, Plaintiffs satisfy 223A, § 3(a) and, so, the long-arm statute.

Section 3(a) permits jurisdiction based on business transacted in Massachusetts only when the plaintiff’s claim arises from the defendant’s transaction of business there.

Putnam v. EPR Properties · filed 2025-08-29(a)

As the Court will not credit “conclusory allegations” or “conclusory averments” without “evidence of specific facts,” and plaintiffs may not “rely on unsupported allegations in their pleadings,” Blanding, 722 F. Supp. 3d at 15 (quoting Platten, 437 F.3d at 134), the Court finds that specific jurisdiction over Defendant EPR is improper under Mass. Gen. Laws ch. 223A, § 3(a).

Section 3(a) requires a Massachusetts business transaction to be a but-for cause of the claim.

Ingle · filed 2025-11-19(a)

To the extent this fact suggests the Sint Maarten Entities have transacted business in Massachusetts, that is insufficient because the long-arm statute requires that the relevant conduct be the but-for cause of Plaintiffs’ injuries, see Cossart, 804 F.3d at 18, that is, that the Sint Maarten Entities transacted business with Plaintiffs through the booking of their reservations while in Massachusetts.

Section 3(a) permits personal jurisdiction over a person for a claim arising from business transacted in Massachusetts by that person or an agent.

Ryan · filed 2025-12-30(a)

Regarding NEFCO GP I and II, § 3(a) of the Long Arm Statute is likewise satisfied on the same basis as NEFCO because the general partners act as agents of NEFCO.

Section 3(a) permits personal jurisdiction when a defendant transacts business in Massachusetts and the claim arises from that transaction.

LendingClub Bank, National Association v. Valley National Bank · filed 2026-03-31(a)

Therefore, because the statute appears to be satisfied, and defendant makes no argument otherwise, the Court finds that the requirements of § 3(a) of the long-arm statute have been satisfied.

Section 3(a)'s transacting business requirement can be satisfied when an out-of-state employer hires someone to work remotely from Massachusetts and regularly communicates with that employee there.

Fuller · filed 2026-03-31(a)

Here, the communications between Fuller and Defendants are sufficient to satisfy the transacting business requirement, because Fuller’s offer letter contemplated that he would work for Carrera & Partners full-time from Massachusetts, and because Fuller then “worked from [his] home office in Medway during [his] entire tenure” with the company, “regularly join[ing] company calls and meetings via videoconference while physically located in Massachusetts.” [Fuller Aff. ¶¶ 2, 5].

Sections 3(a) and 3(b) permit personal jurisdiction over an out-of-state school that offers and provides online courses to Massachusetts students.

High Expectations LLC v. KPCA Northwestern Presbyterian Theological Seminary · filed 2025-09-03(a), (b)

The court finds that KPCA’s conduct amounts to transacting business and contracting to supply services in Massachusetts sufficient to satisfy sections 3(a) and 3(b) of the long-arm statute.

Section 3(a) permits personal jurisdiction when a defendant participates remotely in business conducted in Massachusetts and the claims arise from that business.

The Giving Back Fund, Inc. v. Pasternack · filed 2026-02-18(a)

Ms. Pasternack is subject to personal jurisdiction in Massachusetts under § 3(a) because she transacted business here by repeatedly participated by videoconference in the Fund’s board meetings held in Massachusetts.

Section 3(b) looks to where goods or services are to be supplied, and a seller that only arranges shipment through an independent carrier does not thereby contract to supply goods in Massachusetts.

Droukas v. Divers Training Academy, Inc. · filed 1978-05-04(b)

We construe the phrase “in this commonwealth” as referring to the place where the services or things are to be supplied, rather than referring to the place of the contracting.

Section 3(a) and (b) cover a seller that transacts business and contracts to supply goods in Massachusetts, even without a physical presence there.

New England Welding Contractors, Inc. v. Hydra-Machinery Sales, Inc. · filed 1989-02-09(a), (b)

The first hurdle is easily cleared in this case as, from the facts stated, it cannot be cognizably disputed that HMS both transacted business and contracted to supply goods in the Commonwealth as this conduct is defined under the long-arm statute. Mass.Gen.Laws ch. 223A, § 3(a) and (b).

A one-time sale of goods to be transferred outside Massachusetts does not establish transacting business or contracting to supply goods in the Commonwealth under § 3(a) or § 3(b).

Hutchinson v. Stewart · filed 1997-04-24(a), (b)

Mr. Hutchinson has not shown that his arrangement with Mr. Stewart amounted to “transacting any business” or “contracting to supply” a good within Massachusetts as required by §§3(a) and 3(b) for exercise of jurisdiction by the Massachusetts court.

Section 3(a) does not authorize jurisdiction over a distributor that supplies a Texas manufacturer when the finished product is bought in New Hampshire; section 3(b) does not apply when the distributor did not contract to supply goods in Massachusetts.

Morel v. Aquablend, Inc. · filed 1997-07-21

Delta has not transacted any business in Massachusetts. It supplied sulfuric acid to Aquablend, a Texas corporation, which in turn manufactured Instant Power Drain Opener. The Morels purchased Instant Power Drain Opener at a Home Depot in New Hampshire. Under the Massachusetts case law interpreting §3(a), Delta Distributors has not made the requisite contact with the forum state. ... Delta did not contract to supply sulfuric acid to Massachusetts nor was Aquablend acting as its agent; as such, plaintiff has not demonstrated that Delta meets the requirements of §3(b).

Section 3(a) and (b) require the claim to arise from the defendant’s Massachusetts business activity or a contract to supply goods or services there; a plaintiff’s unilateral payments from Massachusetts do not establish that connection.

Boston Scientific Corp. v. Bonzel · filed 2001-02-20(a), (b)

Under the Massachusetts long-arm statute, Mass. Gen. Laws ch. 223A, § 3, this Court may exercise personal jurisdiction if the plaintiffs’ cause of action arises out of Bonzel’s transacting business or contracting to supply goods or services, in Massachusetts. ... The long-arm statute is not satisfied here. In particular, the claims of Scientific and Scimed cannot be said to arise out of Bonzel’s transacting business within Massachusetts.

Section 3(b) covers a contract to supply services in Massachusetts when the defendant knows the services will be performed there and the claim arises from the contract.

Perkins v. Ryals · filed 2007-09-06(b)

Ryals did, however, contract to supply his services in Massachusetts. While the contract did not specifically mention that services were to be performed in Massachusetts, they were to be performed wherever Perkins played basketball. The plaintiff has sufficiently established that, at least for the 2006-2007 season, those services would be performed in Massachusetts, and that Ryals was aware of that at the time the contract at issue was signed. The dispute between these parties arises from that contract within the meaning of the statute.

Section 3(b) permits personal jurisdiction over a party that contracts to supply digital goods and services in Massachusetts, even without an express requirement to deliver them there.

Nasuni Corporation v. ownCloud GMBH · filed 2022-06-14(b)

The plain language of Mass. Gen. Law c. 223A, § 3(b) provides this Court with jurisdiction over ownCloud. ... While there is no factual allegation that the contract included a requirement to “specifically deliver or supply the receivables to the Commonwealth[,]” the facts support the conclusion that the PBA was a “contract to supply” goods and services in Massachusetts given the digital quality of those deliverables.

Section 3(g) applies retroactively to establish personal jurisdiction in a separate support proceeding that remains pending.

Kennedy v. Kennedy · filed 1980-06-27(g)

On the questions reported, therefore, we answer: that the defendant George D. Kennedy is subject to the jurisdiction of the Probate Court under G. L. c. 223A, §§ 2, 3(a), and by the retroactive application of § 3(g); that George did not satisfy the residence conditions of Arizona law and the divorce decree there granted is, therefore, not valid.

Section 3(g) requires a plaintiff seeking to modify a divorce judgment to continue residing in Massachusetts before the court may exercise personal jurisdiction over a nonresident defendant.

Morris v. Morris · filed 1988-08-01(g)

However, the statute contains an additional requirement for invoking the court’s jurisdiction in a divorce modification action. In such a case, the “plaintiff [must] continue[ ] to reside within the commonwealth.” G. L. c. 223A, § 3 (g).

Section 3(g) requires a resident plaintiff to invoke long-arm jurisdiction for obligations or modifications of alimony, custody, child support, or property settlement.

Tick v. Tick · filed 1988-08-01(g)

The plaintiff failed to meet the threshold jurisdictional requirement of the Massachusetts long arm statute. Actions as “to all obligations or modifications of alimony, custody, child support or property settlement,” where long arm jurisdiction is sought over the defendant, must be instituted by a resident plaintiff. G. L. c. 223A, § 3 (g) (1986 ed.).

Section 3(g) permits personal jurisdiction over a nonresident in an action to modify or enforce a divorce support order only if the parties’ marital domicil was in Massachusetts for at least one year during the two years before the action began.

Westcott v. Westcott · filed 1990-04-04(g)

Section 3 (g) is available as a basis for personal jurisdiction over a nonresident party, in actions to modify a support order or to hold the nonresident in contempt of a support order entered in a divorce judgment, only if the parties’ marital domicil had been “within the commonwealth for at least one year within the two years immediately preceding the commencement of the action.” In the case before us, the court could not obtain personal jurisdiction over the husband under § 3 (g) because the parties to the divorce had not lived as husband and wife in Massachusetts for one year within the two years before the plaintiff brought her action.

Section 3(h) authorizes personal jurisdiction to enforce a child support order after the obligor leaves Massachusetts when the court had personal jurisdiction when it issued the order and the plaintiff and child continue to reside in Massachusetts.

Packard v. Packard · filed 1993-05-27(h)

Given that the child support order that the plaintiff seeks to enforce emanates from a divorce action in which the Probate Court exercised personal jurisdiction over the defendant, there is no question that the assertion of similar jurisdiction in the contempt actions brought in the same court is authorized by G. L. c. 223A, § 3(A).

Section 3(h) permits continuing jurisdiction to enforce a child support order after a child reaches majority only for a reasonable period.

Heider v. Heider · filed 1993-06-22(h)

The continuing nature of the obligation requires that the right to seek its enforcement also continue beyond the attainment of majority for a period reasonable in the circumstances of the particular case. ... If such a great passage of time did not work to change the nature of the action from one seeking enforcement of John’s child support obligation to an action to collect monies owed by John to Anita, it certainly worked to bring the present proceedings to a stage beyond which § 3(h) reasonably can be said to pertain.

Section 3(g) permits personal jurisdiction over a nonresident spouse when the divorce claim arose while the spouses maintained a marital domicile in Massachusetts; the claimant must establish facts showing that connection.

Windsor v. Windsor · filed 1998-10-22(g)

Its plain language would confer jurisdiction over the nonresident husband here only if the wife could demonstrate, at the time of the motion to dismiss, that the cause of action for the 1995 divorce arose while the parties maintained a marital domicile in Massachusetts, namely from 1959 to 1966. She failed, however, to allege, much less to establish, any facts bringing the husband within § 3(g).

Section 3(g) permits personal jurisdiction over a former spouse for alimony and marital property claims arising from a marriage during which that spouse was domiciled in Massachusetts.

Akinci-Unal v. Unal · filed 2005-08-08(g)

Rather, it is the marital relationship in Massachusetts from 1988 to 1994 that has given rise to the wife’s economic claims, and that thus places those claims squarely within the scope of G. L. c. 223A, § 3(g).

Section 3(g) permits personal jurisdiction over a spouse whose conversations in Massachusetts give rise to a divorce claim, even if both spouses were not domiciled there.

Miller v. Miller · filed 2007-02-09(g)

Because we conclude that the statute’s plain language does not require that a husband and wife both be domiciled in the Commonwealth at the time an act giving rise to a claim for divorce occurs, and that the requirements of due process have been met in this case, the judge properly found that the wife has met her burden to prove that the court has personal jurisdiction over the husband.

Section 3(g) permits personal jurisdiction over a nonresident spouse whose acts in Massachusetts give rise to a claim for divorce, alimony, or property settlement.

Cherin v. Cherin · filed 2008-07-30(g)

In any event, we conclude that the husband committed acts in Massachusetts that gave rise to the wife’s claim for divorce, and that the court had jurisdiction under the second ground.

Section 3(h) permits personal jurisdiction over a nonresident obligor to enforce unpaid child support after the child reaches majority, while the unpaid support remains enforceable.

Lombardi v. Lombardi · filed 2007-03-12(h)

With child support orders now enforceable without time constraints other than those imposed by G. L. c. 260, § 20, jurisdiction to implement such enforcement may be obtained either under the long-arm statute, specifically G. L. c. 223A, § 3(h), or, as in the present case, under UIFSA, specifically G. L. c. 209D, § 2-201(1) (in-hand service within the Commonwealth).

Section 3(d) does not establish personal jurisdiction from telephone calls alone, and § 3(g) does not cover a protective-order claim merely because the same complaint requests custody.

Caplan v. Donovan · filed 2008-01-17(d), (g)

The mere fact of making telephone calls, even five or six calls per day, does not by itself create a tortious injury in the Commonwealth. ... The plaintiff’s claim for a protective order is not one of the types of claims listed in § 3 (g). Nor does the presence of a claim for custody confer personal jurisdiction over the defendant with respect to a protective order merely because the two claims are presented in the same document.

Section 3(h) does not confer personal jurisdiction over a separate child support action that neither modifies nor enforces a prior support order.

Sullivan v. Smith · filed 2016-12-16(h)

Thus, the present matter does not come within the provisions of our long-arm statute, G. L. c. 223A, § 3(h), applying to actions involving the "modification" of child support orders.

Section 3(a) permits personal jurisdiction over successor trustees when the claim arises from the settlor’s Massachusetts transactions and the trustees act as his personal representatives, even if they have no Massachusetts contacts of their own.

Nile v. Nile · filed 2000-08-29(a)

Before personal jurisdiction can be exercised over a foreign defendant under G. L. c. 223A, § 3, due process requires that “there was some minimum contact with the Commonwealth which resulted from an affirmative, intentional act of the defendant, such that it is fair and reasonable to require the defendant to come into the State to defend the action.” ... It is immaterial that Nile’s successor trustees had no contacts with Massachusetts. Nile had the requisite contact, so jurisdiction extends to the trustees as his personal representatives.

Section 3 permits jurisdiction over an insurer that contracts to provide defense and indemnity in Massachusetts when a covered event there was reasonably foreseeable at the time of contracting.

National Union Fire Insurance v. Concord Group Insurance · filed 2006-08-17(b), (f)

Having contracted to provide a “service” in Massachusetts, Concord falls within the reach of subsection 3(b) of the longarm statute. ... Thus this court adopts the reasoning of American Home and concludes that the statutory language of subsection 3(f) does not require that the “risk” be realized at the time of contracting, but rather, requires only that it be reasonably foreseeable at the time of contracting; that an insured might, during the period of coverage, be involved in a covered event while in Massachusetts.

Section 3(a) and (d) allow personal jurisdiction over corporate officers based on their own substantial Massachusetts activities related to the claims.

Cahaly v. Benistar Property Exchange Trust Co. · filed 2007-04-17

The record supports the judge’s findings of significant contacts and substantial activities in Massachusetts by both Carpenters, including activities related to the claims asserted by the plaintiffs, see G. L. c. 223A, § 3(a), (d), and the arguments to the contrary are without merit.

Section 3(b) permits jurisdiction over a liability insurer that foreseeably must provide defense services in Massachusetts, and § 3(f) permits jurisdiction when it contracts to insure a risk located there.

Nolan v. Barr & Barr, Inc. · filed 2010-05-10(b), (f)

According to two persuasive decisions, a liability insurance contract constitutes a contract to supply services in Massachusetts for the purposes of G.L.c. 223A, §3(b). ... Alternatively, G.L.c. 223A, §3(f) applies to Diyden as a result of its contract to insure a risk located in Massachusetts at the time of contracting.

Section 3(f) can apply when an insurer contracts to cover a person located in Massachusetts, even if the insurer contracts with someone else.

D.F. Pray, Inc. v. Wesco Insurance Company · filed 2023-09-14(f)

But neither the language of clause (f), nor any case cited by the parties, requires that an insurer have contracted directly with a person in the Commonwealth in order for that clause to apply.

A contingent beneficial interest in trust real estate is insufficient to establish personal jurisdiction under § 3(e).

Smith v. Aiken · filed 2009-02-13(e)

Finally, Khooshe’s contingent beneficial interest in the irrevocable trust is not a sufficient property interest on which this court can base its jurisdiction. ... Presently, Khooshe may neither use nor possess any of the realty in Richard’s irrevocable trust. G.L.c. 223A, §3(e).

Section 3(e) permits personal jurisdiction over executors when a claim arises from a decedent’s interest in Massachusetts real property, including an undischarged mortgage.

Mojtabai v. Mojtabai · filed 2021-07-02(e)

Thus, Fatemeh's allegations that her sisters have refused to agree to discharge the mortgage suffice to show that the Count Two claims arise from the testator's interest in Massachusetts property, such that the Massachusetts long-arm statute is satisfied with respect to those claims.

Section 3 authorizes courts, but not administrative agencies, to exercise personal jurisdiction over nonresidents.

Bulldog Investors General Partnership v. Secretary of the Commonwealth · filed 2010-07-02

By its terms, the long-arm statute applies only to courts and cannot authorize an agency to exercise personal jurisdiction over nonresidents.

Section 3(a) does not govern personal jurisdiction in a federal bankruptcy adversary proceeding.

Baldiga v. Joint Stock Co. (In Re Cyphermint, Inc.) · filed 2011-02-22(a)

The defendants premise their argument of lack of personal jurisdiction on the Massachusetts long-arm statute, Mass. Gen. Laws ch. 223A, § 3(a) which confers personal jurisdiction “over a person, who acts directly or by an agent, as to a cause of action in law or equity arising from the person’s ... transacting any business in” Massachusetts. The Massachusetts long-arm statute is not applicable to these proceedings, however.

Section 3 requires a plaintiff in a federal case without nationwide service of process to establish that the defendant is subject to personal jurisdiction under Massachusetts law.

Chavira v. OS Restaurant Services, LLC · filed 2019-09-30

Accordingly, the Plaintiff must establish that Defendants are subject to personal jurisdiction under the terms of Massachusetts’ long-arm statute.

Section 3(b) applies to contracts for services to be rendered in Massachusetts, regardless of where the contract was formed.

Chouinard v. Marigot Beach Club and Dive Resort · filed 2021-06-03(b)

The former does not apply because “in this commonwealth” refers to the place where the services were to be rendered, not the place where the contract was formed. Here, the services were to be rendered in St. Lucia, not Massachusetts.