Karen M. Suber v. VVP Services, LLC, et al.

The questions presented are: Whether the courts sitting in New York have inconsistently interpreted and applied the standard for the “arising from” prong of the New York LongArm Statute by (i) in some circumstances, applying a standard based on a graduated spectrum marked by degrees of relatedness, defined by an “articulable nexus,” on one end of the spectrum, and by a “substantial relationship” toward the other end of the spectrum, (ii) in other circumstances, collapsing those two phrases — “articulable nexus” and “substantially related” — into one standard, thereby making the phrases synonymous when, by their plain meanings, they are not synonymous, and (iii) in still other circumstances, using a wide variety of other non-synonymous phrases to define the relatedness standard required for the “arising from” prong of the New York Long Arm Statute, yielding an indefinite and imprecise set of standards in violation of the Due Process Clauses of the Fifth and Fourteenth Amendments of the U.S. CONSTITUTION. Whether the New York Long-Arm Statute necessarily must be coextensive with the Due Process Clause of the Fourteenth Amendment of the U.S. CONSTITUTION to guarantee the same due process rights to New York citizens as those due process rights afforded to citizens of other co-equal States within the United States.