After my January 6 posting on the personal jurisdiction issue, I began to wonder how well reported decisions in Maryland fit into the parameters set out in that opinion. I came across the case of Christian Book Distributors, Inc. v. Great Christian Books, Inc., 137 Md. App. 367, 768 A.2d 719 (2001). That case held that (i) the "transacting any business in a state" basis for asserting personal jurisdiction would support the assertion of jurisdiction over a corporation that had allegedly committed a tortious injury by sending a misrepresentation into a state via telex or telephone (and, presumably, e-mail as well), but (ii) personal jurisdiction could not be exercised over an individual who allegedly committed the tortious act, so long as the individual was acting in the scope of his or her employment for the corporation. It is of note that the court went to some lengths to point out that even the limited contact that would support an exercise of jurisdiction in a fraud case would not suffice to support jurisdiction with respect to other claims, such as claims for negligence and breach of contract.
Of course, this does not address the exact question the Fourth Circuit was presented with. In that case, the plaintiff was seeking to enforce an alleged settlement agreement that it contended had been negotiated, at least in part, in the forum state.