Affirming the Limits of New York’s Long-Arm Jurisdiction in Cross-Border Educational Services

Introduction

Goldman v. Trinity School of Medicine is a 2025 decision by the United States Court of Appeals for the Second Circuit. The plaintiff, Jack Goldman, a New York resident, sued Trinity School of Medicine, a Caribbean institution located in St. Vincent and the Grenadines, for alleged false statements during his recruitment interview, improper tuition charges, breach of contract, and violation of New York General Business Law § 349. The District Court dismissed Goldman's complaint for lack of personal jurisdiction under Federal Rule of Civil Procedure 12(b)(2). On appeal, Goldman challenged that dismissal and the denial of leave to amend. The Second Circuit affirmed.

Summary of the Judgment

The Second Circuit held, as a matter of first impression under New York’s long-arm statute (C.P.L.R. § 302(a)(1)), that Trinity’s limited contacts with New York were insufficient to support specific personal jurisdiction. Goldman's allegations—that Trinity had conducted occasional recruiting visits to New York, maintained a past contractual relationship with an Illinois placement company, engaged in general marketing efforts, and enrolled a modest percentage of New York students—did not demonstrate purposeful availment of New York’s privilege. The court also upheld the District Court’s refusal to grant leave to amend the complaint, deeming any amendment futile, and declined to consider, for the first time on appeal, Goldman's request to transfer the case.

Analysis

1. Precedents Cited

Porina v. Marward Shipping Co. (521 F.3d 122): Established de novo review of personal-jurisdiction dismissals.
D.H. Blair & Co. v. Gottdiener (462 F.3d 95): Confirmed that, in diversity cases, personal jurisdiction is governed by forum-state law and due process standards.
N.Y. C.P.L.R. § 302(a)(1): New York’s “transacts any business” long-arm provision.
Al Rushaid v. Pictet & Cie (28 N.Y.3d 316): Clarified that specific jurisdiction requires both purposeful transaction of business and that the claim “arises from” those transactions.
Daou v. BLC Bank, S.A.L. (42 F.4th 120): Reinforced Al Rushaid’s two-prong test for specific jurisdiction.
Licci ex rel. Licci v. Lebanese Canadian Bank (673 F.3d 50; 20 N.Y.3d 327): Held that sporadic, nationwide conduct does not amount to purposeful availment and that a contract must be sufficiently related to the claim.
Ehrenfeld v. Bin Mahfouz (9 N.Y.3d 501): Emphasized the “overriding criterion” of purposeful availment for § 302(a)(1).
McGowan v. Smith (52 N.Y.2d 268): Introduced the “articulable nexus” requirement between the forum contacts and the claim.
Best Van Lines, Inc. v. Walker (490 F.3d 239): Found that general marketing (e.g., a website) without specific targeting is insufficient.
Apicella v. Valley Forge Mil. Acad. (478 N.Y.S.2d 663): Applied the same principle to educational institutions’ general outreach.
Paterno v. Laser Spine Inst. (24 N.Y.3d 370): Confirmed that general recruitment statistics do not establish purposeful availment.
ATSI Communications, Inc. v. Shaar Fund, Ltd. (493 F.3d 87): Set the abuse-of-discretion standard for denial of leave to amend.
Panther Partners Inc. v. Ikanos Communications, Inc. (681 F.3d 114): Declared that denial of leave to amend on futility grounds is reviewed de novo.
Bogle-Assegai v. Connecticut (470 F.3d 498): Held that appellate courts normally do not consider arguments raised for the first time on appeal.

2. Legal Reasoning

The court applied New York’s specific personal-jurisdiction framework. To establish jurisdiction under C.P.L.R. § 302(a)(1), a defendant must (1) purposefully transact business in New York, and (2) have the plaintiff’s claims “arise from” those transactions.

Recruiting Interviews: Trinity conducted a handful of in-state recruitment visits from 2016 to 2018. The court found these visits too sporadic and part of a national campaign to constitute purposeful availment. A transient visit by a corporate representative does not suffice.

Illinois Placement Contract: Trinity’s old contract (ended in 2015) with an Illinois-based clinical-placement company lacked any articulable nexus to Goldman's 2016–2024 claims; Goldman never attended New York rotations.

Marketing and Enrollment: Website advertising, email blasts, and the fact that 7% of students hail from New York were generalized efforts, not purposely directed at the New York market.

Because none of these contacts established purposeful availment or nexus to Goldman’s claims, the Second Circuit held that the District Court correctly dismissed for lack of personal jurisdiction.

Leave to Amend: Having permitted jurisdictional discovery, the District Court found no plausible new facts to plead. Under Panther Partners, amendment would be futile, so its denial was proper.

Transfer of Venue: Goldman’s belated request for a venue transfer was not preserved below, and under Bogle-Assegai, the court refused to consider it.

3. Impact

Goldman v. Trinity School of Medicine underscores the high bar for asserting specific personal jurisdiction over foreign entities in New York. Its clear articulation of the “purposeful availment” and “articulable nexus” requirements will guide:

International educational institutions evaluating their exposure to U.S. courts;
Plaintiffs in consumer-fraud and contract disputes involving cross-border transactions;
Lower courts in applying § 302(a)(1) and distinguishing general marketing from targeted conduct.

Complex Concepts Simplified

Specific Personal Jurisdiction: The power of a court over a non-resident defendant based on the defendant’s activities directed at the forum state.
Long-Arm Statute (C.P.L.R. § 302(a)(1)): New York law authorizing courts to reach non-residents who transact business in the state.
Purposeful Availment: A defendant must deliberately engage with the forum so that it “should reasonably anticipate being haled into court” there.
Articulable Nexus: A logical connection between the forum contacts and the plaintiff’s cause of action.
Futility of Amendment: If proposed new allegations cannot cure jurisdictional defects, leave to amend may be denied.
Venue Transfer: Moving a case to a more appropriate district; must be requested in the trial court.

Conclusion

Goldman v. Trinity School of Medicine affirms that isolated recruitment activities, outdated contracts, and broad marketing programs do not satisfy New York’s specific jurisdiction requirements. The decision reinforces the necessity of both purposeful availment and a direct nexus to the plaintiff’s claims. For practitioners and litigants, it is a reminder to assess jurisdictional strategy at the outset and to preserve venue arguments below. As cross-border service providers expand their outreach, this ruling will serve as a critical benchmark for jurisdictional analysis under New York law.