Clarifying Purposeful Availment and Nexus Requirements under CPLR §302(a)(1): Goldman v. Trinity School of Medicine

Introduction

Goldman v. Trinity School of Medicine, decided April 14, 2025 by the United States Court of Appeals for the Second Circuit, addressed whether a New York court could assert specific personal jurisdiction over Trinity School of Medicine (a Caribbean institution) and twenty unnamed employees. Plaintiff‐appellant Jack Goldman, a New York resident who matriculated at Trinity in 2016, brought claims under New York General Business Law § 349, breach of contract and breach of express warranty based on allegedly false recruitment statements and improper tuition charges. The district court dismissed for lack of personal jurisdiction, and this appeal followed.

Summary of the Judgment

The Second Circuit, in a summary order, affirmed the district court’s dismissal under Federal Rule of Civil Procedure 12(b)(2). It held that Trinity’s limited recruiting visits, a defunct contract with an Illinois placement service, general marketing to unspecified jurisdictions and a small percentage of New York students did not amount to “transacting business” in New York. Without purposeful availment or an articulable nexus between New York contacts and Goldman’s claims, specific jurisdiction under N.Y. C.P.L.R. § 302(a)(1) could not be established. The court also affirmed the denial of leave to amend as futile and declined to consider a venue‐transfer argument raised for the first time on appeal.

Analysis

Precedents Cited

Porina v. Marward Shipping Co., Ltd., 521 F.3d 122 (2d Cir. 2008) – de novo review standard for personal‐jurisdiction dismissals.
D.H. Blair & Co., Inc. v. Gottdiener, 462 F.3d 95 (2d Cir. 2006) – forum‐state long‐arm statute plus due process requirements.
Al Rushaid v. Pictet & Cie, 28 N.Y.3d 316 (2016) – specific jurisdiction requires transactions in the forum and claims arising from them.
Daou v. BLC Bank, S.A.L., 42 F.4th 120 (2d Cir. 2022) – reaffirming Al Rushaid standard.
Licci ex rel. Licci v. Lebanese Canadian Bank, SAL, 673 F.3d 50 (2d Cir. 2012) – “purposeful availment” and “transitory presence” limitations.
Ehrenfeld v. Bin Mahfouz, 9 N.Y.3d 501 (2007) – criteria for “transacting business”.
Licci v. Lebanese Canadian Bank, SAL, 20 N.Y.3d 327 (2012) – “relatedness” or “articulable nexus” requirement.
McGowan v. Smith, 52 N.Y.2d 268 (1981) – nexus between forum transactions and the claim.
Best Van Lines, Inc. v. Walker, 490 F.3d 239 (2d Cir. 2007) – general marketing insufficient for purposeful availment.
Apicella v. Valley Forge Military Academy & Junior College, 478 N.Y.S.2d 663 (2d Dep’t 1984) – recruitment‐based jurisdiction analysis in educational settings.
Paterno v. Laser Spine Institute, 24 N.Y.3d 370 (2014) – targeted marketing versus general solicitation.
ATSI Communications, Inc. v. Shaar Fund, Ltd., 493 F.3d 87 (2d Cir. 2007) – abuse‐of‐discretion standard for denial of leave to amend.
Panther Partners Inc. v. Ikanos Communications, Inc., 681 F.3d 114 (2d Cir. 2012) – futility as a basis to deny leave to amend.

Legal Reasoning

The court applied the two‐pronged test for specific jurisdiction under New York’s long‐arm statute (C.P.L.R. § 302(a)(1)) and due process:

Purposeful Availment / Transacting Business
Trinity’s handful of recruiting interviews in New York (2016–2018) were part of a nationwide campaign, involved no New York office or employees, and ceased after 2018. Under Licci ex rel. Licci and Ehrenfeld, a corporate official’s temporary presence is not enough.
Nexus Between Contacts and Claims
Trinity’s prior contract (terminated 2015) with an Illinois clinical‐placement firm had no connection to Goldman’s 2016–2024 tuition disputes or alleged misrepresentations. The “articulable nexus” requirement from Licci v. Lebanese Canadian Bank and McGowan was unmet.
General Marketing and Enrollment Data
Trinity’s website, e-mail outreach, and the fact that 7% of its students hail from New York were broad, non‐targeted efforts. Under Best Van Lines and Paterno, these do not prove purposeful availment.

Having found no jurisdictional facts, the court held that granting leave to amend would be futile (Panther Partners) and refused to consider venue transfer arguments raised first on appeal.

Impact

This decision reinforces the narrow scope of New York’s long‐arm jurisdiction over out-of-state defendants:

Foreign educational institutions must establish real, deliberate engagement within the state to be haled into New York courts.
Plaintiffs cannot rely on sporadic recruiting visits or generalized marketing to establish specific jurisdiction.
The “articulable nexus” requirement is strictly applied to prevent suits untethered from the forum‐state contacts.

Future litigants and courts will look to this case when evaluating jurisdiction over entities with limited or nationwide‐style outreach.

Complex Concepts Simplified

Personal Jurisdiction – A court’s power to decide a case against a defendant based on the defendant’s connections to the forum state.
Specific Jurisdiction – Exists when a defendant’s purposeful activities in the forum give rise to the plaintiff’s claim.
C.P.L.R. §302(a)(1) – New York’s law authorizing jurisdiction over non–New York residents who transact business within the state and have claims arising from those transactions.
Purposeful Availment – The deliberate targeting of a forum’s market or residents so that invoking jurisdiction is fair.
Articulable Nexus – A clear link between in‐state activities and the legal claim; prevents “jurisdictional fishing expeditions.”
Futility of Amendment – When proposed new allegations cannot cure a jurisdictional deficiency, leave to amend may be denied.

Conclusion

Goldman v. Trinity School of Medicine crystallizes the Second Circuit’s insistence on purposeful availment and an articulable nexus for specific jurisdiction under New York’s long‐arm statute. The ruling serves as a caution to out-of-state entities that occasional recruiting trips and generalized marketing will not subject them to New York jurisdiction without a direct link to the plaintiff’s claims. The decision, though non-precedential, delivers valuable guidance on the limits of New York’s jurisdictional reach and underscores the futility doctrine in amendment motions.