After receiving an email inquiry, Cliff Kraesig agreed to sell Ronald Lewis a rare baseball card.
Upon its receipt, Lewis questioned the card's authenticity and sought a full refund of the purchase price. Kraesig agreed to do so upon the card's return.
When Kraesig failed to refund the money, Lewis sued Kraesig for breach of contract.
Even though Kraesig alleged that baseball card had not been returned (thus justifying his refusal to refund the purchase price), the Suffolk County District Court opted to dismiss the case on "jurisdictional" grounds.
Kraesig was a Kentucky resident, and pursuant to New York State law, a District Court may only exercise its powers over a non-resident of Suffolk County when that party "transacts any business within a district of the court in the county."
In order for this law to be triggered there must be some connection or "nexus" between the business transacted and the cause of action pursued. And a "minimum contacts" must be satisfied.
According to the AT2, since Lewis interacted with Kraesig only by way of email, Kraesig could not establish the required nexus or "contact" with Suffolk County, thus depriving that court of the requisite authority to resolve the dispute.
Clearly, there are a bunch of cards in the collectible market.
For a copy of the Appellate Term's decision, please use this link: Lewis v. Kraesig