Muckle v. Superior Court

Andrew and Cassandra Muckle (defendant and plaintiff) married in Georgia in 1989 but later lived in California; Andrew eventually bought a home in Georgia, moved there permanently, and Cassandra briefly joined him before returning to California and filing for dissolution there, claiming the Georgia home as community property. Andrew, who by then had lived in Georgia since 1998, worked and paid taxes there, held a Georgia driver's license, and was registered to vote there, moved to quash service for lack of personal jurisdiction; Cassandra's unsupported supplemental response alleged Andrew had maintained sufficient California contacts by working there for ten years, receiving California workers' compensation, and using those funds toward the Georgia home purchase. The trial court denied Andrew's motion, relying on Cassandra's unsupported allegations, and Andrew sought a writ of mandate.

Whether a state court may exercise personal jurisdiction over a nonresident in a marital dissolution action if the nonresident has sufficient minimum contacts with the forum state.