James J. MacKey v. Compass Marketing, Inc.

Summary

The court held that Maryland recognizes the conspiracy theory of personal jurisdiction and adopted a four-part standard for applying it. Under that standard, forum contacts of one co-conspirator may be attributed to an out-of-state co-conspirator when the alleged conspirators could reasonably expect the conspiracy to produce consequences in the forum, a co-conspirator commits qualifying overt acts there, and those acts would independently support jurisdiction under the long-arm statute.