Engel V. Geary
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A South Dakota resident, Abby Engel, commenced a divorce action against nonresident defendant Collin Geary in South Dakota. Geary objected to the jurisdiction of the South Dakota court and the sufficiency of the service of process. The court dismissed Geary’s objections and entered a divorce judgment in Engel's favor, dividing the couple's property and imposing certain financial obligations on Geary. Geary appealed, arguing that the court lacked personal jurisdiction over him and thus could not make orders affecting him or his property interests.
The Supreme Court of the State of South Dakota reversed the lower court's decision. The Court found that the lower court lacked personal jurisdiction over Geary as he had not purposefully availed himself of the privilege of conducting activities in South Dakota, and the cause of action did not arise from his activities directed at South Dakota. The Court also determined that the lower court erred when it divided the parties' property and imposed financial obligations on Geary, despite lacking personal jurisdiction over him. The Court concluded that while the lower court had jurisdiction to grant Engel a divorce, it did not have jurisdiction to adjudicate Geary's property interests or impose financial obligations on him.
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