This is a personal jurisdiction case, something that I know a little bit about, having taught the subject in Civil Procedure for a quarter century or so.
On the merits, Section I of the opinion correctly cites the "Principles of Personal Jurisdiction," though one might have wanted to cite McGee in there as well given its close similarity to the present case. (Rather than include merely a "cf" cite way later in the opinion.) Reasonable people could disagree about whether Section II.A. of the opinion is right; namely, whether the defendant law firm here purposefully reached out to California during its legal representation of a California resident.
But Section II.B is definitely wrong. If there's purposeful availment here, the lawsuit definitely "arises out or relates to" -- or has a "substantial connection with" -- those contacts with California. The fact that the (allegedly crappy) work was done in Virginia, or that there was no actual lawsuit filed here yet, wouldn't matter. The fact that the firm (allegedly) reached out to Virginia and solicited a client here definitely has a relation to the malpractice claim -- both causally (but for that relationship, there'd be no malpractice) as well as proximately. After Bristol-Myers, the "substantial connection" test exists, and clearly is satisfied here.
Sez me, anyway.
