Tricarichi v. Coöperatieve Rabobank, U.A.
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The Supreme Court affirmed the orders of the district court dismissing Michael Tricarichi's fraud, conspiracy, and racketeering claims against Respondents, holding that Tricarichi failed to establish personal jurisdiction.
Tricarichi brought this action alleging that Respondents lured him into an intermediary tax shelter scheme that left him liable as a transferee for a multimillion federal tax deficiency and penalty. The district court dismissed Tricarichi's claims for lack of personal jurisdiction over Respondents. The Supreme Court affirmed, holding (1) the district court correctly determined that Respondents lacked minimal contacts with Nevada to satisfy due process and support personal jurisdiction; and (2) Nevada's long-arm statute encompasses a conspiracy-based theory of personal jurisdiction, which this Court adopts as a basis upon which specific jurisdiction may lie, but Tricarichi failed to establish personal jurisdiction under that theory.
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