Establishing Personal Jurisdiction Over Foreign Institutions: Goldman v. Trinity School of Medicine

Introduction

Goldman v. Trinity School of Medicine arose when Jack Goldman, a New York citizen and former student of Trinity School of Medicine—a Caribbean institution located in Kingstown, St. Vincent and the Grenadines—sued the school and twenty unnamed employees under New York General Business Law § 349, breach of contract, and breach of express warranty theories. Goldman alleged that during his recruitment and enrollment (beginning in 2016) he was misled about residency opportunities and charged improper tuition. He filed suit in the Eastern District of New York claiming that Trinity had sufficient contacts with New York to support personal jurisdiction under New York’s long-arm statute (CPLR § 302). The District Court dismissed for lack of personal jurisdiction and denied leave to amend; on April 14, 2025 the Second Circuit affirmed.

Summary of the Judgment

The Second Circuit reviewed de novo the dismissal under Federal Rule of Civil Procedure 12(b)(2).
It confirmed that New York’s long-arm statute (CPLR § 302(a)(1)) requires (a) purposeful availment by the defendant and (b) a nexus between the defendant’s New York activities and the plaintiff’s claim.
The Court held that Trinity’s sporadic recruitment interviews in New York, a terminated pre-2016 clinical placement contract, general marketing and enrollment statistics did not amount to “transacting business” or “purposeful availment.”
The absence of any office, employee or ongoing New York operations, together with the lack of a sufficiently direct connection between activities and the alleged misrepresentations, doomed specific jurisdiction.
The District Court’s refusal to grant leave to amend was affirmed as amendment would be futile—Goldman had no additional facts to supply—and his venue-transfer argument was forfeited.
Judgment of the District Court was affirmed.

Analysis

Precedents Cited

The Second Circuit relied on a series of well-established authorities to articulate the personal-jurisdiction standard:

Porina v. Marward Shipping Co. (521 F.3d 122, 126 [2d Cir. 2008]) – De novo review of personal jurisdiction dismissals.
D.H. Blair & Co., Inc. v. Gottdiener (462 F.3d 95, 104 [2d Cir. 2006]) – Forum state law and due process govern in diversity cases.
Al Rushaid v. Pictet & Cie (28 N.Y.3d 316, 323 [2016]) – To invoke CPLR § 302(a)(1), there must be purposeful availment plus that the claim “arise from” the transacted business.
Licci ex rel. Licci v. Lebanese Canadian Bank, SAL (673 F.3d 50, 61–62 [2d Cir. 2012]) – The “overriding criterion” is purposeful availment; “transitory presence” of an official is insufficient.
McGowan v. Smith (52 N.Y.2d 268, 272 [1981]) – Requires an “articulable nexus” between the defendant’s in-state activity and the plaintiff’s claims.
Best Van Lines, Inc. v. Walker (490 F.3d 239, 250–52 [2d Cir. 2007]) – General advertising or a passive website cannot alone establish purposeful availment.
Apicella v. Valley Forge Military Academy (478 N.Y.S.2d 663, 665–66 [2d Dep’t 1984]) and Paterno v. Laser Spine Institute (24 N.Y.3d 370, 380–81 [2014]) – Enrollment statistics or generalized recruitment across states do not suffice.
ATSI Communications, Inc. v. Shaar Fund (493 F.3d 87, 108 [2d Cir. 2007]) and Panther Partners Inc. v. Ikanos Communications Inc. (681 F.3d 114, 119 [2d Cir. 2012]) – Standards for denial of leave to amend where amendment is futile.
Bogle-Assegai v. Connecticut (470 F.3d 498, 504 [2d Cir. 2006]) – Appellate forfeiture of venue-transfer arguments not raised below.

Legal Reasoning

The core inquiry under CPLR § 302(a)(1) is whether Trinity “purposefully availed itself of the privilege of conducting activities within New York,” and whether Goldman’s claims “arise from” such in-state activities. The court addressed each alleged contact:

Recruitment Interviews: Trinity’s handful of visits (2016–2018) were part of a broader national campaign, not a New York‐specific strategy, and no ongoing presence exists. The “transitory presence” doctrine bars jurisdiction based on occasional interviews.
Clinical Placement Contract: The prior agreement with an Illinois intermediary ended before Goldman’s admission; Trinity had no direct relationship with New York hospitals during the relevant period, severing any nexus.
Marketing Efforts: Website and email outreach, untargeted to New York, cannot substitute for purposeful availment.
Enrollment Statistics: That 7% of Trinity’s students are New Yorkers merely reflects recruitment breadth, not targeted in-state business.

Lacking both an articulable nexus and purposeful availment, Trinity’s New York contacts fell short of § 302(a)(1) demands. The court therefore properly dismissed for lack of specific jurisdiction.

On the leave-to-amend issue, Goldman was afforded jurisdictional discovery but presented no new facts that could cure the jurisdictional defect. Amendment was thus futile under Panther Partners. His belated request for transfer of venue was never raised below and is accordingly forfeited.

Impact

Goldman v. Trinity School of Medicine reaffirms a strict application of New York’s long-arm statute to foreign educational entities. It sends three key messages:

Isolated or sporadic recruitment activities, without an ongoing in‐state operation or targeted outreach, will not satisfy purposeful availment.
Claims must be tied to the very in-state transactions relied upon for jurisdiction; remote or antecedent contracts with intermediaries are insufficient.
Plaintiffs unable to demonstrate additional jurisdictional facts—even after discovery—face dismissal with prejudice and may not later raise venue‐transfer claims on appeal.

Future litigants should carefully assess whether a foreign institution’s activities in New York cross the threshold from general marketing to direct, purposeful engagement before filing suit.

Complex Concepts Simplified

Personal Jurisdiction: A court’s power to make decisions binding a particular defendant. Without it, any judgment is void.
Specific Jurisdiction: Arises when a lawsuit “relates to” or “arises out of” the defendant’s in-state activities.
Long-Arm Statute (CPLR § 302(a)(1)): Allows New York courts to reach non-residents who “transact any business” in the State, provided the lawsuit stems from those transactions.
Purposeful Availment: The defendant must have deliberately engaged in significant activities within the forum state, invoking its protections and markets.
Nexus Requirement: The plaintiff’s cause of action must be connected to the in-state business dealings, not based on unrelated conduct.
Futility in Amendment: A proposed amendment is “futile” if it cannot survive a motion to dismiss; courts won’t grant leave when no viable new theory or facts exist.

Conclusion

Goldman v. Trinity School of Medicine crystallizes the limitations of New York’s long-arm reach over foreign educational institutions. Even well‐grounded claims of misrepresentation and improper charges cannot anchor jurisdiction absent deliberate, New York-focused conduct and a clear link between in-state activities and the asserted legal wrongs. The decision underscores the necessity for plaintiffs to marshal jurisdictional facts early and for defendants to anticipate and challenge tenuous venue bases. In the broader legal landscape, this decision reinforces due-process guardrails on state-court jurisdiction over out-of-state actors.