Cook Associates v. Lexington United Corp.
Illinois Supreme Court
429 N.E.2d 847 (1981)
Cook Associates (plaintiff), an Illinois employment agency, sued Lexington (defendant), a Delaware corporation based in Missouri, for a placement fee after a Cook employee who had left to start her own agency helped Lexington fill a position with a candidate Cook had originally referred; Lexington's only Illinois contacts were exhibiting at three Chicago trade shows (where it could not sell merchandise) and an earlier unsuccessful interview with the same candidate. The trial court found personal jurisdiction and ruled for Cook, but the court of appeals reversed, and Cook appealed, arguing jurisdiction existed under both Illinois's long-arm statute and the due-process minimum-contacts standard.
Whether a state court is bound to equate its long-arm statute and other jurisdictional standards with the satisfaction of the minimum-contacts requirement for due process when determining its personal jurisdiction over a non-resident defendant.