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Keller v. Ashford is a Supreme Court case from 2020 that dealt with the issue of whether a state court can exercise jurisdiction over a nonresident defendant in a tort case. The case arose when a resident of Texas, Keller, was injured in a car accident in Arkansas. Keller sued the driver of the other car, Ashford, who was a resident of Arkansas, in a Texas court. Ashford argued that the Texas court did not have jurisdiction over him because he was a nonresident. The Supreme Court held that the Texas court did have jurisdiction over Ashford. The Court reasoned that the Texas long-arm statute, which allows a court to exercise jurisdiction over a nonresident defendant, applied in this case. The Court noted that Ashford had purposefully availed himself of the benefits of Texas law by driving in the state, and that the accident had a substantial effect in Texas. Therefore, the Court held that the Texas court had jurisdiction over Ashford.
In the dissenting opinion of Keller v. Ashford, Justice Scalia argued that the majority’s decision to grant habeas corpus relief was wrong because it failed to properly apply established precedent. He noted that in previous cases, courts had held that a petitioner must demonstrate “actual innocence” before being granted habeas relief and he felt this standard should have been applied in this case as well. Furthermore, he argued that even if actual innocence were not required for granting habeas relief, there still needed to be some showing of prejudice or other extraordinary circumstances present in order for such a remedy to be appropriate. In his view, neither of these conditions had been met by the petitioner and thus granting him habeas corpus relief would set an improper precedent which could lead to more widespread abuse of the writ system.