Circuit Splits Reported in U.S. Law Week—May 2024

U.S. Law Week summarizes selected splits among U.S. federal courts of appeals each month.

Civil Procedure

Case:

AMB Media LLC v. OneMB LLC, 2024 BL 158056 (Article)

Issue:

For purposes of jurisdiction, does a company’s single electronic sale constitute purposeful availment of a forum where the plaintiff generated the sale? The Sixth Circuit doesn’t decide the issue, but notes that the Seventh Circuit says that a single sale is purposeful availment. The Eighth Circuit disagrees.

Constitutional Law

Case:

360 Virtual Drone Servs. LLC v. Ritter, 2024 BL 172056 (Article)

Issue:

What is the proper level of scrutiny for ...