In a federal diversity case, a gardener sues a homeowner in State B in a federal court seated in State A. The State A long-arm statute would not reach the homeowner. Should the federal court have personal jurisdiction over the homeowner?

• A. Yes, because the 100-mile bulge rule applies in all federal cases
• B. Yes, because federal courts may exercise jurisdiction regardless of state long-arm
• C. No, because FRCP 4(k)(1)(A) requires applying the state's long-arm; if it wouldn't reach, no jurisdiction
• D. No, because Erie commands the state long-arm controls all personal jurisdiction

Answer: (C)

In a federal diversity case, personal jurisdiction over a nonresident defendant is governed by Rule 4(k)(1)(A): a federal court may exercise jurisdiction over a defendant only to the extent the forum state’s courts could do so, i.e., subject to the forum state’s long-arm statute and the Due Process Clause. Here, the federal court sits in State A and the homeowner is in State B, and State A’s long-arm statute would not reach the homeowner. Since the federal court’s authority to bind the homeowner is tethered to what State A’s long-arm would allow, there is no basis for personal jurisdiction in the federal court. The 100-mile “bulge” rule does not override this limitation in a simple diversity scenario; it applies only in narrow circumstances and does not create jurisdiction where the forum state’s long-arm cannot reach. Erie does not change this because personal jurisdiction is a procedural matter governed by Rule 4 and the related state-law constraints, not a matter fixed by Erie’s choice-of-law doctrine.