The Pennsylvania Superior Court held that LifeCycle Construction Services is not subject to specific personal jurisdiction in Pennsylvania. LifeCycle and Bean Sprouts had a contractor/subcontractor relationship for work on five different out-of-state projects. Bean Sprouts filed an amended complaint in Pennsylvania, alleging LifeCycle had breached contracts by withholding money owed to Bean Sprouts for work completed. LifeCycle filed preliminary objections, arguing that LifeCycle did not have the requisite minimum contacts with Pennsylvania, and, therefore, Bean Sprouts did not have personal jurisdiction over LifeCycle in Pennsylvania. The trial court granted the POs, and the Superior Court affirmed. The Court concluded that “despite the parties’ long-term relationship, the trial court did not err or abuse its discretion in finding that Bean Sprouts failed to establish, under the totality of the circumstances, LifeCycle has sufficient minimum contacts with Pennsylvania to justify the exercise of personal jurisdiction.”
