PATRICK J. O'CONNOR; MARIE M. O'CONNOR; Appellants, v. SANDY LANE HOTEL CO., LTD., 496 F.3d 312

Summary

While receiving a massage treatment at the Barbados hotel, the husband slipped, fell, and injured his shoulder. He and the hotel had arranged for that massage by telephone after the hotel mailed a spa brochure to his Pennsylvania home. The instant court found that the hotel deliberately reached into Pennsylvania to target two of its citizens. The instant court reasoned that after plaintiffs' initial stay, the hotel continued to cultivate the relationship by mailing seasonal newsletters to their Pennsylvania home. Next, the instant court found that the hotel's Pennsylvania contacts were a but-for cause of the husband's injury. The husband's affidavit claimed that he decided to purchase spa treatments "as a result" of the hotel's solicitation. Thus, but for the mailing of the brochure, the husband never would have purchased a massage, and he would not have suffered a massage-related injury. Finally, the instant court found that the hotel failed to present a compelling case of ...