United States District Court, District of Alaska
In National Union Fire Insurance Co. of Pittsburgh v. Aspen Custom Trailers, Inc., 587 F.Supp.3d
904 (D. Alaska 2022), the district court held that a non–Alaska company cannot be sued in an
Alaska court when its only connection to the state is a contract with an Alaska company that it
executed outside of Alaska. (Id. at 910–11). An Alaska company bought a trailer assembly from a
Canadian company and completed the entire transaction in Alberta, Canada. (Id. at 907, 910–11).
The trailer assembly broke five years later and the Alaska company filed an insurance claim with
a Pennsylvania company, which sued the Canadian company in Alaska district court. (Id. at 907).
The Canadian company moved to dismiss the case, arguing that it was not subject to personal
jurisdiction in Alaska even though it knew its customer would use the assembly in the state. (Id.
at 907, 912). The district court agreed, reasoning that the Canadian company did not purposefully
avail itself of the benefits of Alaska’s laws as required by the Due Process Clause of the
Constitution. (Id. at 910). The court noted that the Canadian company completed the entire
transaction outside of Alaska and that the United States Supreme Court had barred personal
jurisdiction in a state based on either a contract alone, foreseeability that the product would end up
in that state, or the foreign company’s history of targeting the United States as a whole. (Id. at
911–13). Thus, the district court dismissed the case, holding that a non–Alaska company cannot be
sued in an Alaska court when its only connection to the state is a contract with an Alaska company
that it executed outside of Alaska. (Id. at 910–11).