JPMorgan Chase Bank, N.A. (“Chase”) appeals the trial court’s dismissal of its action against Desert Palace, Inc. (“Caesar’s”) and Opbiz, LLC (“Aladdin”) (together, the “Casinos”) for lack of personal jurisdiction and on grounds of forum non conveniens. Chase raises the following restated issues on appeal:
(1) Whether the Casinos have sufficient minimum contacts to satisfy due process.
(2) Whether Indiana is an inconvenient forum for Chase’s action against the Casinos.
Conclusion (slip op. at 13, 15): The trial court erred in dismissing Chase’s claim for lack of personal jurisdiction . . . [and] abused its discretion in ruling Indiana is an inconvenient forum. Reversed.
Key Analysis (slip op. at 13, 14): We conclude that if the Casinos cashed a marker each knew was not properly authorized by the Indiana account holder . . . a defendant should reasonably anticipate being haled into an Indiana courtroom for tortiously converting an Indiana citizen’s money . . . Indiana courts can only decline litigation due to forum when it is likely to create a “substantial injustice” to the defendant. A mere inconvenience to a corporate defendant’s employees does not create the type of injustice necessary to warrant a dismissal on forum non conveniens grounds.