Cannington v. Cannington
Court of Appeals of Virginia
384 S.E.2d 618 (Va. Ct. App. 1989)
After separating from her husband John (plaintiff), Jodelle Cannington (defendant) remained in Maryland with their son while John moved to Virginia; the son regularly visited John and his parents in Virginia, and Jodelle herself traveled there periodically for personal business and to transport the child. When Jodelle asked John to arrange a Houston trip, he booked a flight departing from Dulles Airport in Virginia (as he had done once before), and when she arrived at Dulles for that flight, John had her served with divorce, custody, and support papers; Jodelle moved to dismiss for lack of personal jurisdiction, claiming John had tricked her into entering Virginia.
Whether a nonresident defendant's presence in a state, sufficient for service of process, subjects her to personal jurisdiction when that presence was not induced through the plaintiff's fraud or trickery.