The majority correctly concludes that defendant’s activities within California are not sufficiently continuous or wide-ranging to subject him to its general jurisdiction. However, the majority incorrectly concludes that plaintiff’s cause of action is sufficiently related to California activity to subject defendant to its limited jurisdiction.
California’s power to compel a nonresident defendant to answer in its courts of law is limited by principles of due process. In essence, due process prohibits a state’s assertion of jurisdiction where it would be unreasonable in light of the defendant’s limited relation to the forum state. (See Internat. Shoe Co. v. Washington, 326 U.S. 310 [90 L.Ed. 95, 66 S.Ct. 154, 161 A.L.R. 1057].)
Whether a defendant not subject to general jurisdiction of a state may nevertheless be subject to limited jurisdiction as to a particular cause of action within the confines of due process turns essentially upon three considerations: (1) whether the cause of action “arises from” or is otherwise “connected with” defendant’s forum-related activities (Buckeye Boiler Co. v. Superior Court, 71 Cal.2d 893, 899 [80 Cal.Rptr. 113, 458 P.2d 57]); (2) the relative burdens upon the parties of tiying the action in the forum state (Travelers Health Assn. v. Virginia, 339 U.S. 643, 649 [94 L.Ed. 1154, 1161-1162, 70 S.Ct. 927]); and (3) the interest of the forum state in assuming jurisdiction (McGee v. International Life Ins. Co., 355 U.S. 220, 223 [2 L.Ed.2d 223, 226, 78 S.Ct. 199]).
Applying these three considerations to the facts at issue, the majority concludes that California may constitutionally assume jurisdiction over defendant as to plaintiff’s cause of action. But let’s look again.
1. Whether Plaintiff’s Cause Of Action “Arises From” Defendant’s Forum-Related Activities
Plaintiff’s cause of action is for wrongful death to her husband. Her action alleges a specific instance of negligent conduct in the operation of *153a motor vehicle on a Nevada highway. Her cause of action in no sense “arises from” the fortuitous fact that defendant has been “engaged in a continuous course of conduct in California.”
Defendant’s continuous activity within California is relevant only to determining whether he is sufficiently “present” within the state to support an assertion of general jurisdiction. But the majority concedes defendant is not subject to general jurisdiction within California. The remaining issue then is whether defendant is subject to jurisdiction limited to this cause of action. As noted above, the appropriate test for “limited jurisdiction” focuses upon the nexus between the cause of action at issue and defendant’s activities within the forum. The connection between plaintiff’s cause of action and the fact that defendant has entered California twice a month for seven years is not shown by the majority, the latter fact being irrelevant to whether defendant was negligent in Nevada.
Equally irrelevant is the fact that “[h]e was not only bringing goods into California for a local manufacturer, but he intended to receive merchandise here for delivery elsewhere.”1
The only conceivable connection between plaintiff’s cause of action and defendant’s activity inside California is that defendant was rolling toward (and plaintiff away from) its border. In this slight sense, the accident arguably “arose” from defendant’s business in the state. However, the majority cites—and research has revealed—no authority supporting the conclusion that such a tenuous connection is sufficient to justify assertion of personal jurisdiction. In fact, the very decisions upon which the majority relies suggest the opposite. Every decision cited by the majority in which an exercise of limited jurisdiction was upheld is one in which the cause of action arose from or was substantially related to defendant’s activity within the forum state itself.2 In the case at issue, *154every event relevant to plaintiff’s cause of action occurred in Nevada. To the extent decisions cited by the majority suggest a single rule, it is one that requires the cause of action relate in some manner to activity defendant has taken within the forum. The application of this rule to the facts at issue requires denial of California jurisdiction.
2. Relative Burdens Upon The Parties In Trying The Action In The Forum State
Excepting plaintiff herself, witnesses to the accident reside in Nevada. In addition, police and medical information as well as physical evidence repose in Nevada. Thus, tiying this action in California places a heavy and expensive burden upon defendant in the presentation of his defense.
The majority claims “there is little difference in the burden between defending in Nevada or California” to a “Nebraska resident faced with litigation outside his state.” This is untrue. The burden on defendant will be significantly increased if he is required to litigate in California when virtually all of the evidence relevant to his defense is located in Nevada. Further, he may be denied the ability to obtain witnesses necessary to the defense. Finally, the mere fact that a defendant who engages in “multi-state activity” may reasonably “expect litigation in distant forums” does not mean he must remain neutral as among the jurisdictions in which he may be required to litigate. Were this otherwise, such defendant would be vulnerable to artful forum shopping.
A second consideration in assessing burdens attendant to tiying an action in the forum state is the ease of access to the alternative forum. (See Fisher Governor Co. v. Superior Court, 53 Cal.2d 222, 225.) But the majority makes no argument that plaintiff would be burdened by having to travel to Nevada to litigate her claim. Such argument would be difficult in light of Nevada’s proximity to plaintiff’s residence.
Consideration of relative burdens upon plaintiff and defendant resulting from tiying this action in California as opposed to Nevada thus clearly suggests Nevada as the more appropriate jurisdiction.
*1553. California’s Interest In Assuming Jurisdiction
The majority asserts—without explanation—that “California has an interest in providing a forum since plaintiff is a California resident.”
A forum’s interest in assuming jurisdiction is a factor often weighed in determining whether jurisdiction may be exercised within the constraints of due process. However, a forum’s interest is generally based upon much more than plaintiff’s mere residence within the forum state. The reasoning of McGee v. International Life Ins. Co., supra, 355 U.S. 220, 223 [2 L.Ed.2d 223, 226], upon which the majority relies, is illustrative: “The contract was delivered in California, the premiums were mailed from there and the insured was a resident of that State when he died. It cannot be denied that California has a manifest interest in providing effective means of redress for its residents when their insurers refuse to pay claims. These residents would be at a severe disadvantage if they were forced to follow the insurance company to a distant State in order to hold it legally accountable. When claims were small . . . claimants frequently could not afford the cost of bringing an action in a foreign forum
Plaintiff’s circumstances here, and California’s resultant interests in providing a forum, are manifestly distinguishable from McGee. Defendant did not engage in any California activity giving rise to the cause of action; rather, plaintiff voluntarily left her state and became involved in a Nevada accident. Further, plaintiff has made no showing she would be at a “severe disadvantage” if required to litigate in Nevada. Finally, the substance of plaintiff’s claim is obviously sufficient to justify the costs of Nevada litigation.
Our busy courts should have little interest in assuring each resident who leaves the state that he may return to litigate every wrong incurred in his travels. The day of the flag following one to Tripoli has passed.
It is plaintiff’s burden to prove facts of jurisdiction by a preponderance of evidence. {Arnesen v. Raymond Lee Organization, Inc., 31 Cal.App.3d 991, 995 [107 Cal.Rptr. 744].) Plaintiff has failed to do so.
The judgment should be affirmed.
McComb, J., and Richardson, J., concurred.
Such fact would be relevant to determining whether California could assert limited jurisdiction in, for example, a cause of action alleging defendant’s fraud in dealing with local manufacturers. It simply is not relevant to an action alleging negligent driving in Nevada.
McGee v. International Life Ins. Co., supra, 355 U.S. 220 (cause of action for breach of contract where defendant solicited and delivered insurance policy within forum state); Buckeye Boiler Co. v. Superior Court, supra, 71 Cal.2d 893 (cause of action for personal injuries resulting from alleged defect in defendant’s product, where defendant marketed such products in forum by direct and indirect sales to forum buyers): Internat. Shoe Co. v. Washington, supra, 326 U.S. 310 (cause of action for tax contributions based upon wages defendant paid employees working within forum state); Travelers Health Assn. v. Virginia, supra, 339 U.S. 643 (cause of action for “cease and desist” order against *154defendant soliciting “mail-order" insurance contracts among forum residents); Martin v. Detroit Lions, Inc., 32 Cal.App.3d 472 [108 Cal.Rptr. 23] (breach of contract cause of action where defendant “scouted,” recruited and signed contract in forum state).