This sounds right to me. I'm not positive it's right. But it nonetheless sounds right.
You (of course) take a risk that when you have sex with someone that it'll result in a pregnancy. (If this is somehow news to you, all I can say is, wow.) Similarly, if you have sex with a woman who resides in California, you (of course) take the risk that she'll potentially have a kid -- your kid -- in California. In the parlance of civil procedure, we'd say that it was "foreseeable" that your act (having sex) would have an effect in California.
But that's not enough for personal jurisdiction. Justice Dato doesn't cite the case in today's opinion, but we know from the Supreme Court's opinion in Worldwide Volkswagen that such a foreseeable effect doesn't establish minimum contacts. When you sell a car, or have sex, the fact that your act could have an effect -- an explosion or a baby -- in the forum state isn't enough.
Now, if you have sex in California, that'd be enough. California sex plus California resident equals California personal jurisdiction. But here, they had sex in Nebraska, not California. Or at least that was the sex that gave rise to the pregnancy -- and we're talking about specific jurisdiction, so we care about the contacts that gave rise to the cause of action, not those contacts (like other sex) that didn't give rise to the child at issue.
Sex in Nebraska, albeit with a California resident, doesn't create specific jurisdiction in California.
As I said, that seems likely right.
The only thing that gives me slight pause in that conclusion is the other (previous) sex between the parties in California. (I agree that the concerts, business trips, etc. in California are totally irrelevant.) I could see an argument that those contacts are sufficiently "related" to the eventual pregnancy -- even though they didn't directly cause it -- to give rise to specific jurisdiction.
But I think the other view -- the one adopted by the Court of Appeal -- seems slightly more persuasive. No purposeful availment with respect to this cause of action. Hence your paternity action needs to be brought where the defendant lives (Connecticut) or, perhaps, where the cause of action indeed arose (Nebraska). You choose.
Fortunately, we have fax machines and airplanes. So not prohibitively difficult.
Even though I concede that it'd obviously be easier for the plaintiff if she could file in California.
