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Civil Procedure Keyed to Field
Cook Associates v. Lexington United Corp
Facts
Plaintiff was an executive employment agency with offices in Chicago and Massachusetts. Defendant was a corporation with its principle place of business in Missouri. McIntosh operated the employment agency, and received a request from Runza, one of Defendant’s executives, for assistance in filling a position. The agreement between the two stated that Defendant would pay Plaintiff a fee if it hired one of Plaintiff’s referrals within two years of the referral. McIntosh sent Hoegemeir to fill the position. He was interviewed in Chicago and offered the position, but turned it down. At some point after this, McIntosh left Plaintiff and established her own employment agency. Runza contacted her again about a position and she again sent Hoegemeir. This time Hoegemeir accepted the offer. Plaintiff sued Defendant in Illinois state court to collect its fee. Defendant challenged the Illinois court’s personal jurisdiction, arguing that its only contact with Illinois was its annual participation in a trade show there. Plaintiff claimed that the original Hoegemeir interview in Chicago formed the basis for a finding that Defendant was doing business in Illinois and was therefore subject to process under the Illinois long-arm statute. The trial court found for Plaintiff and the appellate court reversed. Plaintiff appealed to the Illinois Supreme Court.
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