A probate court has jurisdiction to hear cases involving wills and estates. It lacks subject-matter jurisdiction to hear contract or criminal cases. So to win, CABA's argument had to convince State Court of Appeals judges that Mustang transacted business in New Mexico. Mustang, of course, argued the other side. CABA and Mustang agreed that their deal involved telephone calls, faxes and mail.
Judges use several tests to resolve issues of personal jurisdiction.
The first of these looks at whether the defendant, as required by statute, transacted business in New Mexico. Phones, faxes and letters weren't enough to do the trick, said the judges. CABA lost again. Even though the court could have stopped here, it decided to keep going. A second test looks at where the deal was made.