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Bohreer v. Erie - 8/16/2007

Arizona Court of Appeals Division One Holds that Arizona Has General Personal Jurisdiction Over a Foreign Corporation That Had Ceased Doing Business in Arizona, but Had Not Withdrawn Its Appointment of the Director of Insurance as an Agent for Service of Process Until After It Had Been Served With the Complaint.


Pursuant to A.R.S. § 20-221(A), Arizona has general personal jurisdiction over a foreign corporation which, at the time of the events leading to a lawsuit, had ceased doing business in Arizona but had not withdrawn its appointment of the Director of Insurance as an agent for service of process until after it had been served with the complaint. The exercise of such jurisdiction comports with due process under Pennsylvania Fire Ins. Co. of Philadelphia v. Gold Issue Mining & Milling Co., 243 U.S. 93 (1917).

Judge Kessler authored the opinion; Judges Portley and Irvine concurred.

Posted On: 8/29/2007