On February 24, 2012, the First Judicial Circuit Court of Union County, Illinois granted a motion to dismiss for jurisdictional defect filed by Reed Armstrong on behalf of its client. Lashawn Wyatt vs. Ivan LaGrand, No. 11-L-25. The case arose out of an automobile accident that occurred in Cape Gerardo, Missouri. Defendant established he committed no act in Illinois giving rise to the cause of action; he was not served in Illinois; the alleged tort occurred outside Illinois; and he was not “doing business” in Illinois, that is, he was not carrying on business activities within the forum state with a fair measure of permanence and continuity, at the relevant time frame. Plaintiff also alleged by affidavit that the defendant had committed an intentional tort in Illinois vicariously through the actions of his insurance company´s claims adjuster over the telephone. The Court rejected plaintiff´s argument that such allegations were sufficient to confer personal jurisdiction on the insured defendant.
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