In Zahl v. Eastland, Zahl sued Eastland, an attorney, alleging legal malpractice. On appeal, Eastland argued the court in New Jersey did not have personal jurisdiction over him. The Appellate Division held that Eastland had sufficient minimum contacts with New Jersey to permit the Law Division to exercise specific personal jurisdiction over him and his associated firms with respect to the plaintiff’s complaint. Moreover, the Court found that Eastland failed to demonstrate some “special or unusual burden” that would make the court’s exercise of its jurisdiction inequitable.