The Validity of Personal Jurisdiction Defenses: Two Different Cases, Two Different Conclusions by Illinois Appellate Courts

Since Daimler AG v. Bauman, personal jurisdiction analysis has continued to shift, with Illinois courts applying increasingly fact-specific scrutiny. Two recent appellate decisions—Higgins v. Blessing Hospital and Brody v. Hoch—illustrate the divide: one rejecting jurisdiction based on limited, indirect contacts, the other finding specific jurisdiction where out-of-state defendants intentionally directed tortious conduct into Illinois. Together, the cases underscore that post-Daimler, personal jurisdiction turns less on labels and more on the precise nature, direction, and consequences of a defendant’s forum-related conduct.