Statute Annotations › North Carolina › N.C. Gen. Stat. § 1-75.4

N.C. Gen. Stat. § 1-75.4

Personal jurisdiction: the cases that interpreted this section

Jurisdiction
North Carolina
Case notes
241
Cited in passing
109
Citing cases indexed
586
Case dates
1973–2026
Screened through
2026-05-06
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No reviewed case has held this section invalid, preempted, superseded or repealed.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.

350 citing cases reviewed of 586 in the citation index: 241 interpreted the section (annotated below), 109 cited it only in passing. Cases filed after 2026-05-06 may not have been reviewed yet.

Have a situation under N.C. Gen. Stat. § 1-75.4?

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

Scope of long-arm jurisdiction

Section 1-75.4 permits personal jurisdiction when a special jurisdiction statute applies, but the exercise of jurisdiction must also satisfy due process.

Tom Togs, Inc. v. Ben Elias Industries Corp. · filed 1986-10-07

We have also held in considering N.C.G.S. § 1-75.4 that the requirements of due process, not the words of the long-arm statute, are the ultimate test of jurisdiction over a non-resident defendant, Chadbourn, Inc. v. Katz, 285 N.C. 700, 208 S.E. 2d 676 (1974), and, following the mandate of the United States Supreme Court, we have rejected any per se rule of long-arm jurisdiction, see Buying Group v. Coleman, 296 N.C. 510, 251 S.E. 2d 610 (1979). Accordingly, we reject plaintiffs contention and proceed to the second step of our analysis.
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Section 1-75.4(3) and (4) provide grounds for personal jurisdiction over nonresident defendants based on a local act or a qualifying local injury, subject to due process limits.

North Carolina v. Alexander & Alexander Services, Inc. · filed 1988-02-26(3), (4)

Specifically, and at a minimum, subsections (3) and (4) of § 1-75.4 provide the basis for which defendants may be brought before the court.
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Section 1-75.4 is construed liberally in favor of personal jurisdiction, subject to due process limits.

Watson v. Graf Bae Farm, Inc. · filed 1990-06-19(5)(c)

The North Carolina “long-arm statute” which controls in this case is N.C.G.S. § 1-75.4. ... It is clear both from the wording of this statute and applicable case law that the provisions of this statute are to be liberally construed in favor of finding personal jurisdiction, consistent with due process limitations.
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Section 1-75.4 permits personal jurisdiction over foreign defendants to the full extent allowed by due process.

Boon Partners v. Advanced Financial Concepts, Inc. · filed 1996-03-06

Because the long-arm statute has been construed to permit the assertion of personal jurisdiction over foreign persons to the full extent allowed by due process under the United States Constitution, ... the court need only address whether the exercise of personal jurisdiction over defendant would comport with the constitutional standards of due process.
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Section 1-75.4 extends North Carolina’s personal jurisdiction to the full extent permitted by federal due process.

DP Environmental Services, Inc. v. Bertlesen · filed 1993-07-28

Since North Carolina’s legislature intended to make available to the North Carolina courts the full jurisdictional powers permissible under federal due process, the normal two-step inquiry merges into one.
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Section 1-75.4 permits North Carolina courts to exercise personal jurisdiction to the full extent allowed by due process.

Long v. Silver · filed 2000-04-28

Therefore, the Fourth Circuit has stated that the normal two step inquiry merges into one, because the North Carolina long-arm statute allows the exercise of personal jurisdiction in all cases where such jurisdiction does not contravene due process. ... Accordingly, personal jurisdiction exists if the Plaintiff can satisfy the second prong of the test — that is, if Hertz Herson has established “minimum contacts” with North Carolina such that requiring them to defend an action in North Carolina would not offend traditional notions of fair play and substantial justice.
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Section 1-75.4 permits personal jurisdiction based on substantial activity in North Carolina or an out-of-state act causing injury in North Carolina while business activities are carried on there.

Strother v. Strother · filed 1995-10-03(1)(d), (4)(a)

We find that these activities constitute “substantial activity” within the meaning of G.S. § l-75.4(l)(d). ... These actions by Pinder outside of North Carolina injured plaintiff in this state at the time business activities were being carried on by UAA(NV) in North Carolina, and thus, personal jurisdiction is appropriately extended under G.S. § l-75.4(4)(a).
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Section 1-75.4 extends personal jurisdiction as far as the Constitution allows.

Essential Housing Development, Incorporated v. Landev Investments, Incorporated · filed 1996-08-13

North Carolina's "long arm statute," N.C. Gen.Stat. § 1-75.4, extends jurisdiction as far as the Constitution allows.
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Section 1-75.4 extends personal jurisdiction to the limits permitted by due process.

Regent Lighting Corp. v. Galaxy Electrical Manufacturing, Inc. · filed 1996-04-29

Since the North Carolina legislature designed the long-arm statute to extend personal jurisdiction to the limits permitted by due process, the two-step inquiry merges into one question: whether the exercise of jurisdiction comports with due process.
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Section 1-75.4 permits personal jurisdiction when a dispute arises from a nonresident defendant’s contacts with North Carolina and those contacts satisfy due process.

Replacements, Ltd. v. Midwesterling · filed 1999-05-04

Based on the foregoing, we find controversy at issue arises from the contacts by MidweSterling in the state of North Carolina, which are sufficient to satisfy the requirements of our long-arm statute and the Due Process Clause. Therefore, the exercise of personal jurisdiction is proper.
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Section 1-75.4 permits personal jurisdiction to the extent allowed by due process, so the statutory and constitutional inquiries merge.

Jim Myers & Son, Inc. v. Motion Industries, Inc. · filed 2001-04-04

However, because “the North Carolina long-arm statute [N.C.Gen.Stat. § 1-75.4] has been interpreted as the legislature’s attempt to allow the exercise of personal jurisdiction in all cases where such jurisdiction does not contravene due process, [the] normal two-step inquiry merges into one.”
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Section 1-75.4 permits personal jurisdiction to the full extent allowed by federal due process.

Hanamint Corp., Inc. v. ALLIANT MARKETING GROUP · filed 2007-03-08

North Carolina’s long-arm statute, N.C. Gen.Stat. § 1-75.4, permits the exercise of personal jurisdiction to the full limits of federal due process.
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Section 1-75.4 extends personal jurisdiction over nonresident defendants to the limits permitted by due process.

Christian Science Board of Directors v. Nolan · filed 2001-07-26

Like those of many other states, North Carolina’s long- arm statute is construed to extend jurisdiction over nonresident defen- dants to the full extent permitted by the Due Process Clause.
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Section 1-75.4 authorizes personal jurisdiction to the outer limits of due process.

Setra of North America, Inc. v. Motorcoach Financial, Inc. · filed 2005-02-24

North Carolina’s long-arm statute, N.C. Gen.Stat. § 1-75.4, extends its reach to the outer limits of due process.
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Section 1-75.4 reaches the constitutional limits of due process, so its personal jurisdiction analysis follows the constitutional analysis.

Laboratory Corp. of America Holdings v. Schumann · filed 2006-09-28

The parties have not presented arguments as to whether jurisdiction under that statute would be proper and the Court will not delve into the matter on its own because the statute has been construed to reach to the constitutional limits of due process. Therefore, the analysis of state law collapses into the analysis of any constitutional issues.
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Section 1-75.4 authorizes personal jurisdiction over nonresident defendants to the full extent due process permits, so statutory authorization turns on minimum contacts with North Carolina.

Lulla v. Effective Minds, LLC · filed 2007-06-19

Accordingly, when evaluating the existence of personal jurisdiction pursuant to [this statute], the question of statutory authorization collapses into the question of whether [the defendant] has the minimum contacts with North Carolina necessary to meet the requirements of due process.
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Section 1-75.4 extends North Carolina's personal jurisdiction to the limits of federal due process, merging the statutory and due process inquiries.

Rossetto USA, Inc. v. Greensky Financial, LLC · filed 2008-07-01

North Carolina's long-arm statute, N.C. Gen.Stat. § 1-75.4, was enacted to make available to the North Carolina courts the full jurisdictional powers permissible under federal due process. Since the North Carolina legislature designed the long-arm statute to extend personal jurisdiction to the limits permitted by due process, the two-step inquiry merges into one question: whether the exercise of jurisdiction comports with due process.
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Section 1-75.4 is construed liberally to authorize personal jurisdiction to the full extent permitted by federal due process.

Allison v. Lomas · filed 2005-08-26

“The provisions of this statute are to ‘be given liberal construction, making available to the North Carolina courts the full jurisdictional powers permissible under federal due process.’ ”
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Section 1-75.4 extends North Carolina courts’ personal jurisdiction to the limits permitted by due process.

Brown v. Refuel America, Inc. · filed 2007-11-06

As discussed above, North Carolina common law interprets G.S. § 1-75.4 to extend jurisdiction to the full extent permitted by the Due Process Clause of the U.S. Constitution.
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Section 1-75.4(1)(d) extends North Carolina’s personal jurisdiction to the full extent permitted by federal due process.

Woods International, Inc. v. McRoy · filed 2006-06-20(1)(d)

This statute has been interpreted as extending to the full extent permitted by the Constitution.
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Section 1-75.4 extends personal jurisdiction to the limits of federal due process, which requires sufficient contacts with North Carolina.

Eaker v. Gower · filed 2008-04-15

North Carolina’s long-arm statute, N.C. Gen. Stat. § 1-75.4, was enacted to make available to the North Carolina courts the full jurisdictional powers permissible under federal due process. Since the North Carolina legislature designed the long-arm statute to extend personal jurisdiction to the limits permitted by due process, the two-step inquiry merges into one question: whether the exercise of jurisdiction comports with due process. ... Based on the record, there is not competent evidence to support a finding of minimum contacts between defendant Gower and North Carolina in order for this State to exercise personal jurisdiction over defendant Gower; therefore, we reverse.
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Section 1-75.4 permits personal jurisdiction based on substantial activity in North Carolina or goods shipped from the state on a defendant’s order; sufficient veil-piercing allegations can support jurisdiction over an alter ego.

Saft America, Inc. v. Plainview Batteries, Inc. · filed 2008-04-15(1)d; (5)d

Plaintiff asserts that personal jurisdiction is proper under several statutory provisions including: (1) N.C. Gen.Stat. § 1-75.4(1)d, permitting exercise of jurisdiction over a defendant "engaged in substantial activity within this State, whether such activity is wholly interstate, intrastate, or otherwise" and (2) N.C. Gen.Stat. § 1-75.4(5)d, which states jurisdiction is proper where action "[r]elates to goods, documents of title, or other things of value shipped from this State by the plaintiff to the defendant on his order or direction." The allegations of plaintiff's complaint support the exercise of personal jurisdiction under either provision, particularly when considered in the context of plaintiff's claim to pierce the corporate veil.
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Section 1-75.4 permits personal jurisdiction to the limits allowed by federal due process.

Broadus v. Delta Air Lines, Inc. · filed 2015-04-28

Under North Carolina’s long-arm statute, N.C. Gen.Stat. § 1-75.4, North Carolina courts are permitted to exercise “personal jurisdiction over a defendant to the outer limits allow*559able under federal due process.”
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Section 1-75.4(4)(a) requires evidence of the defendant’s solicitation or services in North Carolina around the time of the alleged injury, while subsection (5)(d) requires a qualifying transfer of something of value from the plaintiff to the defendant.

Gao v. Sinova Specialties, Inc. · filed 2016-12-21(4)(a), (5)(d)

There is no evidence of e-mails, letters, telephone calls, or any other communications from Calder to Sinova US that could be considered solicitations. ... Without more, the Court cannot conclude that Gao has prima facie established jurisdiction under N.C. Gen. Stat. § 1-75.4(4)(a). ... Although wire transfers constitutes a “thing of value” under the statute, see Baker v. Lanier Marine Liquidators, Inc., 187 N.C. App. 711, 714, 654 S.E.2d 41, 44 (2007), there is simply no evidence of any wire transfer from Sinova US to Calder.
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Section 1-75.4 permits personal jurisdiction to the limits of federal due process, so the jurisdictional inquiry proceeds directly to the constitutional analysis.

WALLACE v. GREYSTAR REAL ESTATE PARTNERS, LLC · filed 2019-09-11(1)(d)

North Carolina’s long-arm statute “permits the exercise of personal jurisdiction over a defendant to the outer limits allowable under federal due process.” Id. (citing N.C. Gen. Stat. § 1– 75.4(1)(d); Dillon v. Numismatic Funding Corp., 231 S.E.2d 629, 630 (N.C. 1977)). The two-prong test therefore “merges into [a] single question” when North Carolina is the forum state, allowing the court to proceed directly to the constitutional analysis.
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Section 1-75.4 extends personal jurisdiction over nonresident defendants to the full extent permitted by due process.

Szulczewski v. Cox Enterprises Inc · filed 2020-04-06

North Carolina’s long arm statute provides for jurisdiction when a corporation is “engaged in substantial activity within [North Carolina]” or when the corporation’s acts or omissions give rise to an action for injury to a person in North Carolina. See N.C. Gen. Stat. § 1–75.4. North Carolina’s long-arm statute has been construed “to extend jurisdiction over nonresident defendants to the full extent permitted by the Due Process Clause.”
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Section 1-75.4(1)d extends personal jurisdiction over nonresident defendants as far as due process permits.

TRIANGLE GRADING & PAVING, INC. v. RHINO SERVICES, LLC · filed 2020-04-30(1)d

North Carolina’s long-arm statute, N.C. Gen. Stat. § 1-75.4(1)d, is construed “to extend jurisdiction over nonresident defendants to the full extent permitted by the Due Process Clause.” Id. (citing Century Data Sys., Inc. v. McDonald, 109 N.C. App. 425, 427, 428 S.E.2d 190, 191 (1993)).
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Section 1-75.4(1)(d) permits general personal jurisdiction when a defendant’s activities in North Carolina are sufficiently continuous and systematic.

Brown v. Meter · filed 2009-08-18(1)(d)

“[G]eneral personal jurisdiction” may be exercised pursuant to N.C. Gen. Stat. § l-75.4(1)(d). ... The present dispute is not related to, nor did it arise from, Defendants’ contacts with North Carolina. As a result, the issue raised in this case involves general rather than specific jurisdiction.
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Section 1-75.4 permits personal jurisdiction to the full extent allowed by due process, so the statutory and constitutional inquiries merge.

Olympus Managed Health Care, Inc. v. American Housecall Physicians, Inc. · filed 2009-09-30

However, because “the North Carolina long-arm statute [N.C. Gen.Stat. § 1-75.4] has been interpreted as the legislature’s attempt to allow the exercise of personal jurisdiction in all cases where such jurisdiction does not contravene due process, [the] normal two-step inquiry merges into one.”
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Subsection (1)(d) permits personal jurisdiction to the limits of federal due process, so the statutory and constitutional inquiries merge.

BeoCare Group, Inc. v. Morrissey · filed 2015-08-18(1)(d)

Since the Complaint asserts personal jurisdiction over Defendants under N.C.G.S. § l-75.4(l)(d), the traditional two-step analysis collapses into one question: is the Court’s assertion of personal jurisdiction over Defendants consistent with the Due Process Clause of the Fourteenth Amendment?
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Section 1-75.4(1)(d) permits personal jurisdiction to the limits allowed by federal due process.

Pathfinder Software, LLC v. Core Cashless, LLC · filed 2015-08-28(1)(d)

North Carolina’s long-arm statute “permits the exercise of personal jurisdiction ... to the outer limits allowable under federal due process.”
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Section 1-75.4 permits personal jurisdiction to the full extent allowed by due process, so the statutory and constitutional inquiries merge.

Advantage Solar, LLC v. Accelerate Solar, LLC · filed 2020-03-13

Since “the North Carolina long-arm statute [N.C. Gen. Stat. § 1-75.4] has been interpreted as the legislature’s attempt to allow the exercise of personal jurisdiction in all cases where such jurisdiction does not contravene due process, [the] normal two-step inquiry merges into one.” Id. (citing Dillon v. Numismatic Funding Corp., 291 N.C. 674, 676, 231 S.E.2d 629, 630 (1977)).
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Section 1-75.4(1) grants personal jurisdiction over a natural person domiciled in North Carolina when served, regardless of where the claim arose.

Songwooyarn Trading Co. v. Sox Eleven, Inc. · filed 2011-06-21(1)

We do not address this issue, as personal jurisdiction exists over Defendant Ahn because he was a resident of Mecklenburg County.
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Section 1-75.4(1)(d) permits personal jurisdiction to the limits allowed by the Due Process Clause.

Marx Industries, Inc. v. Chestnut Ridge Foam, Inc. · filed 2012-10-12(1)(d)

This two-part inquiry collapses into one, where, as here, jurisdiction is asserted pursuant to N.C. Gen.Stat. § 1-75.4(1)(d), which North Carolina courts have interpreted to permit the exercise of personal jurisdiction to the outer limits allowable by the Due Process Clause of the United States Constitution.
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Section 1-75.4(1)(d) permits personal jurisdiction to the limits of federal due process, so the statutory inquiry turns on whether the defendant has sufficient contacts with North Carolina.

Universal Leather, LLC v. KORO AR, S.A. · filed 2014-12-08(1)(d)

Thus, because personal jurisdiction in the present case is asserted under N.C.G.S. § 1-75.4(1)(d), our two-prong test merges into the single question whether Universal has made a prima facie showing that Koro had sufficient contacts with North Carolina to satisfy constitutional due process.
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Section 1-75.4(1)(d) permits personal jurisdiction over a nonresident defendant only when the defendant’s North Carolina contacts satisfy due process.

Wright v. Zacky & Sons Poultry, LLC · filed 2015-05-15(1)(d)

The Fourth Circuit recently confirmed its interpretation of North Carolina’s long-arm statute, holding that the issue of specific jurisdiction under N.C. Gen.Stat. § 1-75.4(l)(d) “merges” the two-prong test “into the single question” of whether a defendant has “sufficient contacts with North Carolina to satisfy constitutional due process.” Universal Leather, 773 F.3d at 558-59. Thus, the single inquiry here is whether the exercise of personal jurisdiction over Zacky “is consonant with the strictures of due process.” Tire Eng’g & Distribution, LLC v. Shandong Linglong Rubber Co., 682 F.3d 292, 301 (4th Cir.2012); see also Universal Leather, 773 F.3d at 558-59. ... Under these circumstances, the exercise of jurisdiction over Zacky would violate due process.
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Section 1-75.4(1)d extends personal jurisdiction over nonresident defendants only as far as due process permits; limited assistance with a North Carolina resident’s power of attorney did not establish sufficient contacts here.

VELEZ v. COLON · filed 2019-09-30(1)d

All the factors point to the conclusion that haling Defendant Colon into a North Carolina court would violate the Due Process Clause of the Federal Constitution and the North Carolina long-arm statute; Defendant Colon could not reasonably foresee having to defend herself in this state by virtue of her limited assistance to Plaintiff in executing a power of attorney.
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Section 1-75.4(1)(d) permits personal jurisdiction to the limits allowed by federal due process.

PET SPECIALTIES, LLC v. NAVISIONTECH, INC. · filed 2019-09-30(1)(d)

North Carolina’s long-arm statute “permits the exercise of personal jurisdiction over a defendant to the outer limits allowable under federal due process.” Id. (citing N.C. Gen. Stat. § 1– 75.4(1)(d); Dillon v. Numismatic Funding Corp., 231 S.E.2d 629, 630 (N.C. 1977)). The two-prong test therefore “merges into [a] single question” when North Carolina is the forum state, allowing the court to proceed directly to the constitutional analysis.
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Section 1-75.4 extends personal jurisdiction over nonresident defendants as far as due process permits.

Gosnell v. Bush · filed 2020-03-10

North Carolina’s long-arm statute extends jurisdiction over nonresident defendants to the full extent permitted by the Due Process Clause and the analysis is under the constitutional standard.
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Section 1-75.4 is construed liberally to reach the limits of personal jurisdiction allowed by due process.

Chi v. N. Riverfront Marina & Hotel Lllp · filed 2022-08-16

However, because North Carolina’s long arm statute “is to be afforded a liberal construction so as to reach the outer limits of personal jurisdiction allowed by due process[,]” Diamond Candles, LLC v. Winter, 2020 NCBC LEXIS 28, at *11 (N.C. Super. Ct. Mar. 12, 2020) (citing Beem USA LLLP v. Grax Consulting, LLC, 373 N.C. 297, 302 (2020)), this two-step analysis often collapses into an inquiry regarding whether due process considerations have been satisfied. ... Therefore, the Court proceeds directly to the due process inquiry.
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Section 1-75.4 extends personal jurisdiction to the limits permitted by federal due process.

VIENT v. SANFORD HERALD · filed 2020-08-07

Under North Carolina’s long-arm statute, N.C. Gen. Stat. § 1-75.4, North Carolina courts are permitted to exercise “personal jurisdiction over a defendant to the outer limits allowable under federal due process.” ... Thus, the two-part inquiry merges into a single question: whether the exercise of jurisdiction comports with due process.
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Section 1-75.4 permits North Carolina courts to exercise personal jurisdiction to the limits allowed by federal due process.

WALL RECYCLING, LLC v. 3TEK GLOBAL, LLC · filed 2020-10-28

Under North Carolina’s long-arm statute, N.C. Gen. Stat. § 1-75.4, North Carolina courts are permitted to exercise “personal jurisdiction over a defendant to the outer limits allowable under federal due process.” ... Thus, the two-part inquiry merges into a single question: whether the exercise of jurisdiction comports with due process.
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Section 1-75.4(1)(d) authorizes personal jurisdiction over a defendant to the extent due process permits.

Miller v. LG Chem · filed 2022-02-01(1)(d)

This statute grants the courts of North Carolina jurisdiction “over defendant[s] to the extent allowed by due process.”
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Section 1-75.4 authorizes personal jurisdiction over nonresident defendants to the full extent permitted by due process.

Atlantic Coast Marine Group, Inc. v. Hannye · filed 2020-09-14

Because N.C. Gen. Stat. § 1- 75.4 “is construed to extend jurisdiction over nonresident defendants to the full extent permitted by the Due Process Clause . . . the dual jurisdictional requirements [set forth in Nolan] collapse into a single inquiry as to whether the defendant has such minimal contacts with the forum state that maintenance of the suit does not offend traditional notions of fair play and substantial justice.” Nolan, 259 F.3d at 215 (internal quotation marks and citations omitted).
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Section 1-75.4 authorizes personal jurisdiction to the full extent allowed by due process, so the statutory and constitutional inquiries merge.

Revel Xp, LLC v. Never Forget Brands, LLC · filed 2022-07-25

“[B]ecause North Carolina's long-arm statute has been interpreted to allow the exercise of personal jurisdiction to the fullest extent allowed under the due process clause, the two-step analysis collapses into one inquiry.”
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Section 1-75.4 authorizes personal jurisdiction to the full extent permitted by federal due process.

North Carolina Ex Rel. Stein v. Bowen · filed 2022-10-27

In practice, the analysis often collapses into one inquiry because the North Carolina Supreme Court has broadly construed the long-arm statute “to make available to the North Carolina courts the full jurisdictional powers permissible under federal due process.” Id. (citation and quotation marks omitted); see also Dillon v. Numismatic Funding Corp., 291 N.C. 674, 676 (1977).
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Section 1-75.4(1)(d) permits personal jurisdiction to the full extent allowed by federal due process.

W.M. Barr & Company, Inc. v. Dumond, Inc. · filed 2022-12-09(1)(d)

North Carolina’s long-arm statute, N.C. Gen. Stat. § 1-75.4(1)(d), “permits the exercise of personal jurisdiction over a defendant to the outer limits allowable under federal due process.”
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Section 1-75.4(1)(d) permits personal jurisdiction to the limits of federal due process.

Umar v. Eubanks · filed 2023-11-02(1)(d)

North Carolina state law governs the instant motion, and “[t]he North Carolina Supreme Court has held that N.C.G.S. § 1–75.4(1)(d) permits the exercise of personal jurisdiction over a defendant to the outer limits allowable under federal due process.” Universal Leather, 773 F.3d at 558. Accordingly, the “two-prong test merges into the single question” of whether Umar has made a prima facie showing that Eubanks and CPA Department had sufficient contacts with North Carolina to satisfy constitutional due process. Id. at 559.
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Section 1-75.4(5) does not require a complaint to cite the statute when its allegations support an inference of personal jurisdiction under it.

Toshiba Glob. Commerce Sols., Inc. v. Smart & Final Stores LLC · filed 2020-12-23(5)

For pleading purposes, that is enough to support an inference of jurisdiction under section 1-75.4(5).
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Section 1-75.4 authorizes personal jurisdiction to the full extent permitted by the United States Constitution.

Bryant v. Core Contents Restoration, LLC · filed 2021-03-30

North Carolina’s courts have said that North Carolina’s long-arm statute, N.C. Gen. Stat. § 1-75.4, authorizes the exercise of jurisdiction to the full extent authorized by the United States Constitution.
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Section 1-75.4(1)(d) permits personal jurisdiction to the full extent allowed by federal due process.

Yacht Basin Provision Company, Inc. v. Bates · filed 2022-07-08(1)(d)

North Carolina’s long-arm statute, N.C. Gen. Stat. § 1-75.4(1)(d), “permits the exercise of personal jurisdiction over a defendant to the outer limits allowable under federal due process.”
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Section 1-75.4 permits personal jurisdiction to the full extent allowed by federal due process.

Moore v. Brooks · filed 2025-11-07

Two principal authorities limit North Carolina courts’ power to exercise personal jurisdiction: the state’s long-arm statute, N.C. Gen. Stat. § 1-75.4, and the Due Process Clause of the Fourteenth Amendment to the United States Constitution. Shaeffer v. SingleCare Holdings, LLC, 384 N.C. 102, 106 (2023). However, the limits those authorities set are, for all practical purposes, identical: the long-arm “statute makes available to the North Carolina courts the full jurisdictional powers permissible under federal due process.” Id. (citation and internal punctuation omitted). Therefore, the Court need only analyze jurisdiction under the Due Process Clause.
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Section 1-75.4 authorizes personal jurisdiction to the full extent permitted by federal due process.

State of N.C. v. Tiktok Inc. · filed 2025-08-19

Jurisdiction must be authorized by the State’s long-arm statute, N.C.G.S. § 1-75.4, and consistent with the Due Process Clause of the Fourteenth Amendment to the United States Constitution. ... In practice, this “two-step analysis” usually collapses into one because our Supreme Court has broadly construed the long-arm statute “to make available to the North Carolina courts the full jurisdictional powers permissible under federal due process.”
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Section 1-75.4 permits North Carolina courts to exercise personal jurisdiction to the full extent allowed by federal due process.

Moore v. Brooks · filed 2026-01-23

However, the limits those authorities set are identical: the long-arm “statute makes available to the North Carolina courts the full jurisdictional powers permissible under federal due process.” Id. (citation and internal punctuation omitted). Therefore, the Court need only analyze its authority under the Due Process Clause.
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Section 1-75.4 reaches as far as due process permits, so the court need only decide whether exercising personal jurisdiction satisfies due process.

Matheson & Associates, PLLC v. Selinsky · filed 2026-02-03

North Carolina’s long-arm statute is coextensive with the due process clause. Christian Sci. Bd. of Directors of First Church of Christ, Scientist v. Nolan, 259 F.3d 209, 215 (4th Cir. 2001). Thus, the Court must only decide whether exercising personal jurisdiction over defendant would offend due process.
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Section 1-75.4 makes personal jurisdiction available to North Carolina courts to the full extent permitted by federal due process.

Ray v. TitleMax of Va., Inc. · filed 2026-02-04

Our Supreme Court has held the provisions of N.C. Gen. Stat. § 1-75.4 are “intended to make available to the North Carolina courts the full jurisdictional powers permissible under federal due process.” ... For the foregoing reasons, we hold Defendants are subject to personal jurisdiction in North Carolina and affirm the trial court’s order.
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Presence in state when served

Section 1-75.4(1)(a) permits personal jurisdiction over a natural person present in North Carolina when served with process.

Berger v. Berger · filed 1984-04-03(1)(a)

Residency notwithstanding, defendant’s contention lacks merit, since the trial court had clear grounds for jurisdiction under our “long-arm” statute, G.S. 1-75.4. Pursuant to G.S. l-75.4(l)(a), defendant was a natural person present within North Carolina when he was served with process on 23 August 1982.
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Section 1-75.4(1)(a) permits personal jurisdiction over a defendant served with process while present in North Carolina when the court has subject matter jurisdiction.

Brookshire v. Brookshire · filed 1988-03-01(1)(a)

G.S. l-75.4(l)(a) permits our state courts, having subject matter jurisdiction, to exercise in personam jurisdiction over a person served with process in accordance with G.S. 1A-1, Rule 4(j) or 4(jl), while present within the State. It is undisputed that defendant was personally served with summons and complaint on 19 July 1985 while present within the State for the purpose of visiting his parents and children in Wilkes County. Therefore, the “long-arm” statute has been satisfied.
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Section 1-75.4(1)(a) permits personal jurisdiction over a natural person present in North Carolina when served under Rule 4(j).

Smith v. Schraffenberger · filed 1988-06-21(1)(a)

On 8 July 1985, defendant was personally served with an alias and pluries summons and a copy of the complaint by a Carteret County Deputy Sheriff, pursuant to N.C. Gen. Stat. § l-75.4(l)(a). ... We hold that the trial court’s denial of defendant’s motions to dismiss should be affirmed.
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Section 1-75.4(1) permits personal jurisdiction when a defendant is served under Rule 4(j) while present in North Carolina or domiciled there.

Sun Bank/South Florida v. Tracy · filed 1991-12-03(1)

Under G.S. § 1-75.4, our “long arm” statute, a court of this state having jurisdiction over the subject matter acquires personal jurisdiction over a defendant when the defendant is served pursuant to Rule 4(j) when he is present in the state, G.S. § l-75.4(l)a, or is domiciled within the state, G.S. § l-75.4(l)b.
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Section 1-75.4(1)(a) permits personal jurisdiction over a nonresident natural person personally served while present in North Carolina.

Hedden v. Isbell · filed 2016-11-01(1)(a)

This manner of service of process satisfies both requirements for establishing personal jurisdiction over Defendant. ... Consequently, when the sheriff’s deputy personally served her, the trial court acquired in personam jurisdiction over Defendant and the need for a minimum contacts analysis was rendered unnecessary.
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Money payments as things of value

Section 1-75.4(5)(d) permits statutory personal jurisdiction based on money payments as things of value, subject to constitutional due process.

Schofield v. Schofield · filed 1986-01-07(5)(d)

This Court has held that money payments are “things of value” within the meaning of G.S. 1-75.4(5)(c). ... The same logic applies to (5)(d). We hold that statutory jurisdiction exists under G.S. 1-75.4(5)(d).
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Section 1-75.4(5)(d) treats payments of money as things of value that can support statutory personal jurisdiction.

Stallings v. Hahn · filed 1990-06-19(5)(d)

Therefore, we hold that statutory jurisdiction exists under G.S. § 1-75.4(5)(d).
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Section 1-75.4(5)(c) permits personal jurisdiction when a defendant promises in a note to make payments to a plaintiff in North Carolina, because the promise is to deliver a thing of value in the state.

Harrelson Rubber Co. v. Layne · filed 1984-07-17(5)(c)

A promise in a note to make payments to a plaintiff in the forum state is a promise to deliver there a thing of value within the meaning of G.S. 1-75.4(5)c.
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Section 1-75.4(5)(c) authorizes personal jurisdiction when a defendant promises to make payments to the plaintiff in North Carolina.

Wohlfahrt v. Schneider · filed 1984-02-21(5)(c)

Obviously, money is a thing of value, and defendant’s promise in the note to make payments to plaintiff in Wilmington, North Carolina was clearly a promise to deliver a thing of value within this state, and thus within the purview of the statute.
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Section 1-75.4(5)c permits personal jurisdiction when a defendant promises to deliver an insurance policy in North Carolina and delivers it there.

Jellen v. Ernest Smith Insurance Agency, Inc. · filed 1984-12-18(5)c

The evidence shows that Ernest Smith promised Tudor Hall that it would write an insurance policy insuring plaintiffs property and deliver the same to Tudor Hall in North Carolina to be forwarded to Mr. Jellen in North Carolina. The promise was kept and the policy was in fact delivered to North Carolina. These actions are sufficient to confer jurisdiction on the North Carolina courts pursuant to G.S. l-75.4(5)c.
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Section 1-75.4(5)(c) permits personal jurisdiction over a contract claim arising from a promise to deliver payment to a recipient in North Carolina.

Harris v. Pembaur · filed 1987-03-17(5)(c)

N.C.G.S. § 1-75.4(5)(c) would therefore apply and our “long-arm statute” allows jurisdiction.
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Section 1-75.4(5)(d) permits personal jurisdiction when a defendant directs a plaintiff to send money from North Carolina and the claim is sufficiently related to those payments.

Cherry Bekaert & Holland v. Brown · filed 1990-08-07(5)(d)

Because defendant directed plaintiff to send his monies to him in Alabama and plaintiff distributed the money from North Carolina, the money paid is ‘shipped from this State by the plaintiff to defendant on his order or direction.’ ... However, both the present controversy and plaintiff’s previous payments to defendant arise from a single contract into which these parties entered, and liberally construed, the present controversy is sufficiently related to the previous payments ‘shipped from this State by the plaintiff to the defendant on his order or direction’ to merit long-arm jurisdiction.
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Section 1-75.4(4)(a) can authorize jurisdiction based on a solicitation sent into North Carolina, and subsection (5)(d) can authorize it based on a payment check sent from the state on the defendant's direction.

Tejal Vyas, LLC v. Carriage Park Ltd. Partnership · filed 2004-09-07(4)(a), (5)(d)

The memorandum sent to plaintiffs' attorney in North Carolina to consider defendants' investment proposal constitutes a solicitation under N.C. Gen.Stat. § 1-75.4(4)(a). ... Also, the $100,000.00 check sent from plaintiffs in North Carolina to defendants in Illinois for payment for one investment unit in Carriage Park constitutes a "thing[ ] of value" shipped from this state by plaintiffs to defendants on their order or direction pursuant to N.C. Gen.Stat. § 1-75.4(5)(d). For either of these two reasons, the defendants are subject to jurisdiction under North Carolina's long-arm statute, N.C. Gen.Stat. § 1-75.4.
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Section 1-75.4(5)(d) authorizes personal jurisdiction when money is wired from North Carolina under a note directing payment to the defendant, even if the defendant did not specify where the money would be sent from.

Mascaro v. Mountaineer Land Group, LLC · filed 2006-11-14(5)(d)

The fact that the Note directed Mountaineer to send money to Harless, (Harless Aff. Ex. 1, June 2, 2006), coupled with the fact that Mountaineer wired the money from a North Carolina bank account means that “the money paid was ‘shipped from this State by the plaintiff to the defendant on his order or direction.’” Cherry Bekaert & Holland, 99 N.C. App. at 631, 394 S.E.2d at 655 (quoting N.C.G.S. § 1-75.4(5)(d)). Whether Harless actually directed Mountaineer to send the funds from North Carolina is irrelevant to this determination. See id. Accordingly, North Carolina’s long-arm statute authorizes jurisdiction over Harless for purposes of this case.
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Section 1-75.4(5)(d) permits personal jurisdiction when a plaintiff ships goods from North Carolina on the defendant’s order or direction, subject to due process.

SIQUAR USA, INC. v. Wang · filed 2009-07-07(5)(d)

In the instant case, there is competent evidence that defendant Sequoia purposefully availed itself of the privilege of conducting activities within North Carolina, by ordering products that were shipped from North Carolina to Florida, and thus invoked the benefits and protections of North Carolina laws. This evidence supports the trial court's presumed factual findings that defendant Sequoia's contacts with North Carolina are sufficient to satisfy N.C. Gen. Stat. § 1.75.4 (5)(d), the long-arm statute, and due process.
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Section 1-75.4(5)(d) treats a buyer’s wire transfer from North Carolina to an out-of-state seller as a thing of value shipped from the state on the seller’s direction.

Baker v. Lanier Marine Liquidators, Inc. · filed 2007-12-18(5)(d)

Moreover, the $9,812 wire transfer sent from plaintiff in North Carolina to defendant, in Georgia, for payment of the boat constitutes a "thing[] of value" shipped from this State by plaintiff to defendant on defendant's order or direction pursuant to N.C. Gen.Stat. § 1-75.4(5)(d).
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Section 1-75.4(5)(d) permits personal jurisdiction when a defendant requests payment and the plaintiff sends it from North Carolina, even if the defendant did not specify where the payment should originate.

Laboratory Corp. of America Holdings v. Caccuro · filed 2011-06-21(5)(d)

In other words, under Cherry Bekaert, all that is required to satisfy N.C. Gen. Stat. § l-75.4(5)(d) is that a defendant demanded money from the plaintiff and the plaintiff paid the money from North Carolina.
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Section 1-75.4(5)(d) authorizes personal jurisdiction when a defendant directs a plaintiff to send a check from North Carolina, subject to a separate due process inquiry.

Miller v. SZILAGYI · filed 2012-06-05(5)(d)

Plaintiff asserts and Defendants do not dispute that pursuant to N.C. Gen. Stat. § l-75.4(5)(d), a component of the North Carolina long-arm statute, the Thompsons are subject to personal jurisdiction because there exists an action related to “goods, documents of title, or other things of value shipped from this State by the plaintiff to the defendant on his order or direction[.]” ... We agree with Plaintiff’s assertion that North Carolina’s long-arm statute authorizes personal jurisdiction over the Thompsons.
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Section 1-75.4 permits personal jurisdiction over a servicing entity that receives disputed funds from a North Carolina bank account as the first transferee.

ITG Brands, LLC v. Funders Link · filed 2022-07-05

As the admitted servicing arm, Funders Link is the “first transferee” of the disputed funds taken from Zoom’s North Carolina bank account and satisfies the North Carolina long-arm statute.
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Section 1-75.4(5)(c) covers a contracting party’s promise to deliver payment for equity interests in North Carolina because money is a thing of value.

Shively v. Aci Learning Holdings, LLC · filed 2025-08-27(5)(c)

Because the Boathouse Defendants assented to the SAR, they promised to deliver to Plaintiff payment for his equity interests. “It is well-established that money is a ‘thing of value’ contemplated under the long-arm statute.” ... Accordingly, the Court determines that the Boathouse Defendants are parties to the SAR and North Carolina’s long-arm statute applies to them.
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Corporate directors and officers

Section 1-75.4(8) authorizes personal jurisdiction over directors and officers of domestic corporations in cases arising from corporate conduct during their service.

Pasquinelli v. Wilson · filed 1988-03-15(8)

Not only does our long-arm statute, G.S. 1-75.4(8), explicitly grant personal jurisdiction over persons who were officers or directors of domestic corporations in cases arising out of the conduct of the corporation while they were directors or officers, but our Business Corporation Act, by appropriate provisions enacted in 1955, subjects all officers and directors of North Carolina corporations, resident and nonresident alike, to the personal jurisdiction of our courts in cases involving either their services or the acts of their corporations during the period of service.
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Section 1-75.4(8) permits personal jurisdiction over an officer or director of a North Carolina corporation for claims arising from that role or the corporation’s activities, subject to due process.

Wilson v. Wilson-Cook Medical, Inc. · filed 1989-08-18(8)

Thus, as long as the exercise of personal jurisdiction over these Defendants does not offend the Due Process Clause of the Fourteenth Amendment, personal jurisdiction over Cook Group may be exercised under N.C.Gen.Stat. § 55-145(a)(4), if Cook Group committed “tortious conduct” in this State, and personal jurisdiction over Cook and Sterner may be exercised as director and officer, respectively, of Wilson-Cook under N.C.Gen.Stat. § 1-75.4(8). ... In the instant action, in personam jurisdiction over Cook Group, Cook and Sterner would not offend “traditional notions of fair play and substantial justice.”
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Section 1-75.4 permits personal jurisdiction over corporate officers when uncontested allegations establish that they were the corporation’s alter egos and that the corporation solicited and received services in North Carolina.

Inspirational Network, Inc. v. Combs · filed 1998-11-03(4)(a), (5)(a), (5)(b)

Therefore, based upon the uncontroverted allegations contained in plaintiff’s complaint and the uncontested statements in Martin’s affidavit, plaintiff came forward with a prima facie showing sufficient to subject Combs and Petree to personal jurisdiction in North Carolina under either G.S. § l-75.4(4)(a) or G.S. § l-75.4(5)(a)&(b).
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Section 1-75.4(4) requires solicitation by or on behalf of the defendant, while subsection (5)(d) requires a transfer to the defendant on his order or direction.

Robbins v. Ingham · filed 2006-10-17(4), (5)(d)

In fact, no statements in J. Robbins’ or T. Robbins’ affidavits, or in the entire record, illustrates that they were solicited by Gamble or on behalf of Gamble. Therefore, we conclude that Gamble is not subject to personal jurisdiction under N.C. Gen. Stat. § 1-75.4(4). ... Nothing in the affidavits illustrate that plaintiffs transferred the money from North Carolina to Gamble on his order or direction. Therefore, we conclude that Gamble is not subject to personal jurisdiction under N.C. Gen. Stat. § 1-75.4(5).
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Section 1-75.4(5) permits personal jurisdiction when a corporation’s contacts with North Carolina, including contacts attributed through an alleged alter ego, satisfy the minimum contacts requirement.

Walker v. White · filed 2009-03-12(5)

Having reviewed the affidavits submitted by plaintiff and considered the legal arguments made by defendants, and it appearing that this court may properly exercise jurisdiction over the persons of the defendants, the undersigned respectfully determines that plaintiff has met its burden; the North Carolina long-arm statute has been satisfied; due process is not offended; and defendant CPBBC, Inc., is properly subject to this court’s jurisdiction.
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Marital relationship

Section 1-75.4(12) permits personal jurisdiction in a Chapter 50 action arising from a marital relationship in North Carolina when the other party continues to reside there, even after the defendant leaves the state.

Powers v. Parisher · filed 1991-11-05(12)

We hold that plaintiff's action meets the dual requirements of subsection 12. First, plaintiff's action is brought "under Chapter 50." ... Second, plaintiff's action "arises out of the marital relationship within this State." ... On these facts the trial court properly concluded that the statutory requirements for personal jurisdiction over defendant were satisfied.
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Section 1-75.4(12) authorizes personal jurisdiction over a nonresident parent in a Chapter 50 custody or support action arising from the parties’ marital relationship in North Carolina.

Harris v. Harris · filed 1991-12-03(12)

Specifically, the statute authorizes our trial courts to render child custody orders against non-resident defendants where, as here, the child custody action under Chapter 50 of the General Statutes arises out of the parties’ marital relationship within this State. ... Because the child support action under Chapter 50 arises out of the parties’ marital relationship within this State, N.C.G.S. § 1-75.4(12) authorizes the exercise of personal jurisdiction over this defendant.
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Section 1-75.4(12) authorizes personal jurisdiction in a Chapter 50 action arising from a marriage in North Carolina when the other spouse continues to reside there, even if the couple never established a permanent home in the state.

Sherlock v. Sherlock · filed 2001-05-01(12)

We agree with the trial court’s conclusion that jurisdiction is proper under this statutory provision. The parties were married in North Carolina. Plaintiff “continues to reside” in North Carolina. The action arises under Chapter 50, “Divorce and Alimony,” and seeks resolution solely of issues pertaining to the dissolution of their marriage. Under these circumstances, plaintiffs action is authorized under G.S. § 1-75.4(12).
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Jurisdiction over corporate parents

Section 1-75.4(1) does not confer personal jurisdiction over a foreign parent merely because it owns a subsidiary; the complaint must allege facts supporting jurisdiction over the parent.

Birtha v. Stonemor, North Carolina, LLC · filed 2012-05-01(1)

In the present case, Plaintiffs contend that N.C. Gen. Stat. § 1-75.4(1) confers jurisdiction because SCI acquired and retains all shares in Alderwoods, a co-defendant. ... Further, the complaint did not allege facts as to activity being conducted within the state by SCI. ... Based on the foregoing, we hold that Plaintiffs failed to allege facts that permitted the inference of jurisdiction under the long-arm statute.
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Section 1-75.4(1) requires facts permitting an inference of personal jurisdiction; alleging only that a corporation owns a co-defendant's shares, without facts showing the corporation's activity in North Carolina, is insufficient.

Hardin v. York Memorial Park · filed 2012-06-19(1)

Similarly, Plaintiffs asserted the section of the long-arm statute in their brief, but failed to state any grounds for personal jurisdiction in their complaint. Further, the complaint did not allege facts as to activity being conducted within the state by SCI. ... Based on the foregoing, we hold that Plaintiffs failed to allege facts that permitted the inference of jurisdiction under the long-arm statute.
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Section 1-75.4 authorizes personal jurisdiction to the full extent permitted by federal due process.

Padron v. Bentley Marine Grp., LLC · filed 2018-12-04

Nevertheless, “our long-arm statute was intended to make available to North Carolina courts the full jurisdictional powers permissible under due process.”
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Section 1-75.4 does not confer personal jurisdiction over a parent company based on its subsidiary’s passive investments in North Carolina companies that neither company owns or controls.

Green Gulf Grp. Fze v. Nat'l Holding, LLC · filed 2014-05-28

Neither EIIC nor Defendant owns or controls the three companies, and a passive investment by Defendant’s subsidiary is not encompassed by the long-arm statute.
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Consent to jurisdiction by registration

Section 1-75.4(1)(c) permits general personal jurisdiction over a foreign corporation that obtains a North Carolina certificate of authority because it is subject to the same liabilities as a domestic corporation.

PDII, LLC v. Sky Aircraft Maint., LLC · filed 2025-12-03(1)(c)

Guided by Mallory, North Carolina statutes, Espin, and Klein, we hold a foreign corporation that obtains a certificate of authority consents to general personal jurisdiction in North Carolina; therefore, we affirm the trial court’s order denying Defendant’s motion to dismiss.
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Agency and personal jurisdiction

Section 1-75.4(5) does not establish personal jurisdiction over a corporation when the plaintiff fails to show that the people who purported to contract for it had authority to bind it.

Marshall Exports, Inc. v. Phillips · filed 1974-01-21(5)

Plaintiff has undertaken to serve Takashimaya with process by serving the summons and complaint on the Secretary ... of State of North Carolina, contending that the Japanese corporation is amenable to effective service under two North Carolina statutes, N.C.G.S. § 1-75.4(5) and N.C.G.S. § 55-145(a)(1). ... Notwithstanding plaintiff’s officers believed in good faith that the two contracts in question were binding obligations of Takashimaya, the fact is that neither Phillips nor Hirose were authorized to bind Takashimaya by these agreements. ... Without this evidence it must be held that plaintiff has fallen short of carrying the burden of establishing that Takashimaya’s activities sufficed to satisfy the requirements of the “minimum contacts” doctrine enunciated in International Shoe Company v. Washington, 326 U.S. 310, 66 S.Ct. 154, 90 L.Ed. 95 (1945), and this defendant’s motion to dismiss must be allowed.
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Presence or domicile in North Carolina

Section 1-75.4(1) allows personal jurisdiction over a person present or domiciled in North Carolina or a domestic corporation.

McFee v. Presley · filed 2022-11-29(1)

In addition, Plaintiffs have offered proof of personal jurisdiction through the verified allegations of the complaint. (See Compl. ¶¶ 3–8; Verification of J. McFee ¶ 3, ECF No. 86.1.) See also N.C.G.S. § 1-75.4(1) (allowing personal jurisdiction over any party who “[i]s a natural person present [or domiciled] within this State” or “a domestic corporation”).
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Notes 151–241 of 241, oldest cases first.

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