Telephone Call Sufficient Contact For Jurisdiction In California.

A California lawyer made a telephone call to an Arizona lawyer to inquire about title and ownership of equipment the California lawyer’s client was contemplating buying from a Texas company. He left a voicemail message, and the Arizona lawyer returned the telephone call. The Arizona lawyer represented he was the lawyer for the Texas company, and that his client was the sole owner of the equipment. Based on the Arizona lawyer’s representations, the California lawyer advised his client to go forward with the equipment purchase. As it turned out, a New York bank also had an interest in the equipment, and the purchaser brought a legal malpractice action against the California lawyer. The California lawyer cross-complained against the Arizona lawyer for equitable indemnity, negligence, intentional and negligent misrepresentation and concealment. The trial court granted the Arizona lawyer’s motion to quash, finding the Arizona lawyer did not purposefully avail himself to benefits in California, commenting: “It seems just such a random attenuated and insufficient contact to establish specific jurisdiction.” In reversing, the Court of Appeal stated: “Clark personally availed himself other benefits of California when he reached into California to induce Moncrief’s client to complete the equipment purchase.” (Moncrief v. Clark (Cal. App. Sixth Dist., July 21, 2015) 238 Cal.App.4th 1000 [189 Cal.Rptr.3d 864].)