Goldman v. Trinity School of Medicine: Clarifying Purposeful Availment for Non-Domiciliary Institutions under CPLR 302(a)(1)

1. Introduction

Goldman v. Trinity School of Medicine (2d Cir. Apr. 14, 2025) addresses whether a Caribbean medical school’s limited recruitment activities and ancillary relationships suffice to confer specific personal jurisdiction in New York under CPLR 302(a)(1). Plaintiff-appellant Jack Goldman, a New York resident who matriculated at Trinity in St. Vincent and the Grenadines, sued the School and twenty unnamed employees for violations of New York General Business Law § 349, breach of contract, and breach of express warranty, all grounded in allegedly false recruiting statements and improper tuition charges. The District Court dismissed for lack of personal jurisdiction; the Second Circuit affirmed.

2. Summary of the Judgment

The Court of Appeals, sitting in summary order, reviewed de novo the District Court’s Rule 12(b)(2) dismissal. It held that:

Trinity’s limited recruitment visits to New York (2016–2018), part of a nationwide campaign, did not demonstrate “purposeful availment” of New York’s market.
A lapsed Illinois-based placement contract was too remote and unrelated to Goldman’s claims to support specific jurisdiction.
Generic marketing materials and the fact that 7% of students hailed from New York did not amount to directed activity within the State.

Because Goldman failed to show an “articulable nexus” between any New York-directed transaction and his claims, the court affirmed dismissal. Leave to amend was denied as futile; no venue transfer was requested below and thus was waived.

3. Analysis

3.1 Precedents Cited

Porina v. Marward Shipping (521 F.3d 122, 126 (2d Cir. 2008)): De novo review standard for personal jurisdiction dismissals.
D.H. Blair & Co. v. Gottdiener (462 F.3d 95, 104): Diversity cases apply forum state long-arm statute plus due process.
Al Rushaid v. Pictet & Cie (28 N.Y.3d 316, 323): Two-part test—transaction of business plus claim arising from that transaction.
Daou v. BLC Bank (42 F.4th 120, 129 (2d Cir. 2022)): Reinforcement of Al Rushaid standard in Second Circuit.
Licci ex rel. Licci v. Lebanese Canadian Bank (673 F.3d 50, 61–62): “Overriding criterion” is purposeful availment; transitory corporate official visits are insufficient.
McGowan v. Smith (52 N.Y.2d 268, 272 (1981)): Requirement of an “articulable nexus” between contacts and claims.
Best Van Lines, Inc. v. Walker (490 F.3d 239, 250–52): Generic website and mass-email campaigns are not purposeful availment.
Apicella v. Valley Forge Military Academy (478 N.Y.S.2d 663, 665–66 (2d Dep’t 1984)): Enrollment statistics alone do not establish directed activity.
Paterno v. Laser Spine Institute (24 N.Y.3d 370, 380–81 (2014)): General advertising does not equate to purposeful targeting of forum state.

3.2 Legal Reasoning

The Court applied New York’s long-arm statute, CPLR 302(a)(1), alongside due process constraints. To exercise specific jurisdiction, Trinity must have:

“Transacted business” in New York by purposeful availment; and
A clear connection between those transacted activities and Goldman’s claims.

Trinity’s handful of recruitment visits, untethered to any ongoing New York operation, failed the first prong. The Illinois placement agreement predated Goldman’s enrollment and lacked any causal tie to his tuition or warranty claims. Finally, broad marketing and mere New York student enrollment reflected a national outreach rather than a deliberate and focused campaign at New York. Without a “relatedness” requirement satisfied, the court found no basis for jurisdiction.

3.3 Impact

This decision reinforces strict limits on personal jurisdiction over foreign or out-of-state educational institutions:

Isolated or transient recruitment activities—even site visits or interviews—do not suffice.
Contracts with third parties (e.g., clinical placement firms) must be directly linked to the plaintiff’s claim to count.
Generalized internet or print marketing, and alumni statistics, are insufficient absent targeted New York outreach.

Future plaintiffs seeking forum jurisdiction over non-domiciliary schools or corporations in New York will need more substantial and direct forum-connected conduct or agreements.

4. Complex Concepts Simplified

Purposeful Availment: A defendant must take deliberate steps to invoke New York’s market or legal protection, not merely appear briefly or indirectly.
Articulable Nexus: A tangible link between the defendant’s New York activities and the legal claim alleged by the plaintiff.
Specific Jurisdiction vs. General Jurisdiction: Specific jurisdiction arises from the suit’s relation to the forum contacts; general jurisdiction requires continuous and systematic activity in the forum.
Futility of Amendment: Where additional factual allegations cannot cure the jurisdictional defect, granting leave to amend is unnecessary.

5. Conclusion

Goldman v. Trinity School of Medicine cements the principle that limited out-of-state recruitment and disconnected third-party contracts cannot alone establish specific personal jurisdiction under CPLR 302(a)(1). The ruling highlights the necessity for plaintiffs to demonstrate purposeful, forum-directed activity and a clear tie between those activities and the legal claims advanced. In doing so, the Second Circuit preserves the due process balance between protecting states’ interests and preventing undue burdens on non-resident defendants.