To ensure a chosen court has solid territorial jurisdiction from the outset, a plaintiff's best practices include conducting exhaustive pre-filing research to confirm that the defendant's residence, business operations, or specific actions—such as signing a contract or committing a tortious act—are substantively connected to the forum, meticulously aligning the complaint's factual allegations with the state's long-arm statute and constitutional due process requirements by demonstrating the defendant purposefully availed themselves of that jurisdiction, and if any uncertainty exists, strategically filing in a potentially more favorable venue to preemptively negate grounds for a dismissal motion.
