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Online Retailer Dispute — Personal Jurisdiction and Removal

Civil Procedure 30 min medium
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Fact Pattern

GreenLeaf LLC is a small organic tea company incorporated in State A with its sole office and warehouse in State A. GreenLeaf sells tea exclusively through its website, which is accessible nationwide. GreenLeaf has no employees, offices, or agents in State B.

Over the past two years, GreenLeaf has shipped approximately 200 orders to customers in State B, generating roughly $15,000 in revenue from State B customers. GreenLeaf's website displays targeted advertisements to State B residents based on IP-address geolocation and offers free shipping to State B addresses during holiday promotions.

Paula Nguyen, a resident of State B, purchased a specialty herbal tea blend from GreenLeaf's website. After drinking the tea, Paula experienced a severe allergic reaction requiring emergency hospitalization. Paula's medical bills total $85,000.

Paula filed a products liability and negligence lawsuit against GreenLeaf in State B state court, seeking $85,000 in compensatory damages and $50,000 in punitive damages. GreenLeaf's attorney filed a motion to dismiss for lack of personal jurisdiction. Alternatively, GreenLeaf seeks to remove the case to federal court.

State B's long-arm statute extends jurisdiction to the fullest extent permitted by the Due Process Clause of the Fourteenth Amendment.

Call of the Question

Does the State B court have personal jurisdiction over GreenLeaf? Discuss both general and specific jurisdiction.

Can GreenLeaf remove the case to federal court? Discuss.