In Riemer v. KSL Recreation Corp., No. 1-01-4347 (March 29, 2004), the First District rejected an argument that plaintiff properly served a corporate defendant by serving a subsidiary. "When a court determines whether a foreign corporation is doing business in this state, the question is not whether its local affiliate is doing business in the jurisdiction, but whether the foreign parent is doing business in the jurisdiction through its local affiliate."
The case contains an extensive summary of the current law concerning constitutional due process and the "minimum contacts" rule. Applying the applicable law, the Court held that the defendant had insufficient contacts with Illinois to subject it to the jurisdiction of the Illinois courts. Among other problems, "Defendant's only contacts with Illinois were through the activities of its sub-subsidiary's Illinois office. However, plaintiffs were never solicited by the Illinois office and their stay at [defendant's] California resort was unrelated to any activity in Illinois. "