“It is well settled that a state's exercise of personal jurisdiction over a nonresident defendant satisfies due process only if the defendant has certain minimum contacts with [the forum state] such that the maintenance of the suit does not offend traditional `notions of fair play' and substantial justice." (See In re Marriage of Crew (1996) 549 N.W.2d 527, 528-29; InternationalShoe Co. v. Washington (1945) 326 U.S. 310, 316, 66 S.Ct. 154, 158, 90 L.Ed. 95, 102; Milliken v. Meyer (1940) 311 U.S. 457, 463, 61 S.Ct. 339, 343, 85 L.Ed. 278, 283.)
"The `minimum contacts' test . . . is not susceptible of mechanical application; rather, the facts of each case must be weighed to determine whether the requisite `affiliating circumstances' are present." (See id; Kulko v. California Super. Ct (1978) 436 U.S. 84, 92, 98 S.Ct. 1690, 1697, 56 L.Ed.2d 132, 141; Hanson v Denckla (1958) 357 U.S. 235, 246, 78 S.Ct. 1228, 1235, 2 L.Ed.2d 1283, 1293.)
Rule 1.421 of the Iowa Rules of Civil Procedure governs motions to dismiss.
“Every defense to a claim for relief in any pleading must be asserted in the pleading responsive thereto, or in an amendment to the answer made within 20 days after service of the answer, or if no responsive pleading is required, then at trial.” (See Iowa R. Civ. P. 1.421(1).)
“The following defenses or matters may be raised by pre-answer motion…(b) Lack of jurisdiction over the person.” (See Iowa R. Civ. P. 1.421(1)(b).)
“We review the district court's denial of …[a] motion to dismiss for legal error.” (See Harding v. Sasso, No. 21-1666, at *4-5 (Iowa Ct. App. Dec. 21, 2022); Sioux Pharm, Inc. v. Summit Nutritionals Int'l, Inc. (2015) 859 N.W.2d 182, 188; Shams v. Hassan (2013) 829 N.W.2d 848, 853.)
“Unlike other grounds for dismissal, a court considering a motion to dismiss for lack of personal jurisdiction must make factual findings to determine whether it has personal jurisdiction over the defendant. The court's legal conclusions and application of legal principles do not bind us. But, if supported by substantial evidence, those factual findings do.” (See id.)
“In reviewing a ruling on a motion to dismiss for lack of personal jurisdiction, this court accept[s] as true the allegations of the petition and the contents of uncontroverted affidavits.” (See In re Marriage of Crew (1996) 549 N.W.2d 527, 528; Percival v. Bankers Trust Co. (1990) 450 N.W.2d 860, 861; State ex rel. Miller v. Internal Energy Management Corp. (1982) 324 N.W.2d 707, 709-10.)
“The plaintiff has the burden to sustain the requisite jurisdiction, but when he [or she] establishes a prima facie case the defendant has the burden of producing evidence to rebut that showing.” (See id.)
“The trial court's findings of fact have the effect of a jury verdict and are subject to challenge only if not supported by substantial evidence in the record; we are not bound, however, by the trial court's application of legal principles or its conclusions of law.” (See id.)
It is well settled that “when resolving jurisdictional questions regarding nonresidents, the allegations of the petition which go to the merits of the claim are taken as true; other allegations in the petition may be contradicted by affidavits, testimony, and other evidence.” (See Meyers v. Kallestead (1991) 476 N.W.2d 65, 66; Lansky v. Lansky (1989) 449 N.W.2d 367, 369; Martin v. Ju-Li Corp. (1983) 332 N.W.2d 871, 873.)
As such, it is also well settled that “the minimum contacts test is not susceptible of mechanical application; each case must be weighed to determine whether affiliating circumstances are present.” (See id.)
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