Rilley v. MoneyMutual LLC
Minnesota Supreme Court
884 N.W.2d 321 (2016)
Scott Rilley (plaintiff), a Minnesota resident, used MoneyMutual LLC's (defendant) website to get a payday loan, providing his home address during registration; MoneyMutual then emailed him, including matching him with a Minnesota-based lender, and separately used Google AdWords to target ads at searches like 'payday loans Minnesota.' Rilley filed a Minnesota class action alleging MoneyMutual's loans there were illegal, and presented evidence MoneyMutual had emailed over 1,000 Minnesota residents. MoneyMutual moved to dismiss for lack of personal jurisdiction; the trial court denied the motion, and MoneyMutual appealed.
Whether a company's email contacts with known residents of a forum state can establish personal jurisdiction over the company there.