dissenting.
Although it is important for Social Services to be able to recover child support costs from fathers, even if they are not residents of Colorado, I do not believe that this cause is furthered by making important decisions about an alleged father's past behavior and future responsibilities without having him legitimately before the court. Such a failure in personal jurisdiction is fundamentally unfair and may result in unreliable determinations. Because I believe the majority's jurisdictional analysis cannot be squared with the due process requirements of the federal and state constitutions, I respectfully dissent.
The question whether sufficient contacts exist with a forum state for it to exercise personal jurisdiction over an absentee respondent is admittedly a flexible and highly fact-specific inquiry. - Kulko v. Superior Court, 436 U.S. 84, 92, 98 S.Ct. 1690, 56 L.Ed.2d 132 (1978). It has, in fact, been characterized as "more an art than a science." Keefe v. Kirschenbaum & Kirschenbaum, P.C., 40 P.3d 1267, 1272 (Colo.2002) (citing Sawtelle v. Farrell, 70 F.3d 1381, 1388 (1st Cir.1995)). Nonetheless, due process of law remains a fundamental requirement.
In order to subject himself to the jurisdiction of a particular state, an absentee respondent must, at the very least, have done something to purposefully avail himself of the benefits and protections of that state's laws. Kulko, 436 U.S. at 94, 98 S.Ct. 1690 (citing Shaffer v. Heitner, 433 U.S. 186, 216, 97 S.Ct. 2569, 53 L.Ed.2d 683 (1977). Although a single act, not even involving personal presence in the state, may be sufficient to support personal jurisdiction for a specific purpose, it must nevertheless be "such that [the respondent] should reasonably anticipate being haled into court there." World-Wide Volkswagen Corp. et al. v. Woodson, 444 U.S. 286, 297, 100 S.Ct. 559, 62 L.Ed.2d 490 (1980). It is this "purposeful availment" requirement that ensures that a respondent *65will not be haled into a jurisdiction solely as a result of random or fortuitous contacts or the unilateral activity of a third party. Kirschenbaum, 40 P.3d at 1271; see also Burger King Corp. v. Rudzewics, 471 U.S. 462, 475, 105 S.Ct. 2174, 85 L.Ed.2d 528 (1985); Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408, 417 n. 17, 104 S.Ct. 1868, 80 LEd.2d 404 (1984) (passive activity of a mere customer within a state is insufficient to confer jurisdiction); Keeton v. Hustler Magazine, 465 U.S. 770, 774, 104 S.Ct. 1473, 79 L.Ed.2d 790 (1984); World-Wide Volkswagen Corp., 444 U.S. at 299, 100 S.Ct. 559 (a finding that a product can be transported to and used in a state is too tenuous a connection).
By focusing solely on the effects or "consequences" of the respondent's alleged conduct, quite apart from any "purposeful availment" on his part, the majority shifts the inquiry from one concerning the respondent's intentionality or reasonable anticipation, to one of mere causation. Compare maj. op. at 63 with maj. op. at 62, and Van Schaack & Co. v. District Court, 189 Colo. 145, 147, 538 P.2d 425, 425 (1975). The majority's inquiry is concerned even with causation only in the sense that another free moral agent was motivated by the respondent's abusive conduct to flee to this state in order to get away from him-an act that was clearly against his wishes and directives. As reasonable and as predictable as the mother's choice may have been, it provides no less tenuous a connection between the alleged father and this state than the connection between a car seller and a state through which the buyer drives the car en route to his home. See World-Wide Volkswagen Corp., 444 U.S. at 299, 100 S.Ct. 559.
In my view, the phrase "acts or directives," as it appears in the Uniform Interstate Family Support Act, section 14-5-201(5), 5 C.R.S. (2003), can withstand constitutional scrutiny only to the extent that it intends no more than verbal directives and acts in the nature of, or in furtherance of, such directives. Reading these words broadly, as the majority does, to extend the state's jurisdiction to cover virtually anyone who does an act that, in some sense, results in his child's residing in this state violates well-established precepts of fundamental fairness and due process of law and, by contrast with the holding of International Shoe,1 actually would "her-alld] the eventual demise of all restrictions on the personal jurisdiction of state courts," Kulko, 436 U.S. at 101, 98 S.Ct. 1690 (citing Hanson v. Denckla, 357 U.S. 235, 251, 78 S.Ct. 1228, 2 L.Ed.2d 1283 (1958)), if allowed to stand.
The UIFSA is clearly aimed at a burgeoning societal problem and justifiably seeks to extend the personal jurisdiction of a child's home state over a non-resident parent as far as constitutionally permitted. However, as I believe its attempts to distinguish previous applications of the statute make clear, the majority is extending personal jurisdiction well beyond any previous construction. Even the Virginia court, upon which the majority heavily relies, found only that the father's specific orders for his wife and child to leave the marital home in Africa, combined with his motion for visitation and petition for a rule to show cause in the state of the previous family home, to which his wife and child had returned, amounted to sufficient contact. See Franklin v. Virginia, 27 Va. App. 136, 497 S.E.2d 881, 887 (1998).
Here, the allegations and testimony of the mother suggest no such directive acts or purposeful contact. The child's mother claimed merely that her less-than-one-year cohabitation with the respondent in Texas amounted to a common-law marriage; that his abusive conduct forced her to flee the marital home; that after leaving the respondent, she discovered that she had very recently become pregnant by him; that several phone calls, made before she even returned to Colorado, evidenced the respondent's awareness that her father lived in Pueblo; and that the respondent's stalking behavior foreed her to flee Texas for her father's home in Colorado. The mother delivered the child in this state almost eight months, by her own account, after separating from the respondent. More than a year later, after seeking public assistance, she petitioned for *66dissolution of the marriage and for child support.2
In the absence of more than a special appearance by respondent's counsel to contest personal jurisdiction, the existence of the marriage, the paternity of the child, and the propriety of the child-support order rested entirely upon the credibility of the mother. Accepting as true all of the mother's allegations, the respondent never attempted to do business in this state; never directed or ac-quieseed in the child's presence in this state; and never personally set foot inside this state. Inconvenient as they may be, legitimate ways do exist for this state to establish the parentage of the child and have child-support obligations imposed upon the father, without haling the respondent into the courts of this state in the absence of purposefully availing himself of the benefits and protections of its laws. And even if they did not, granting a monetary award against the respondent in absentia would be no less unacceptable.
I would therefore affirm the judgment of the court of appeals.
I am authorized to state that Justice MARTINEZ and Justice BENDER join in this dissent.
. International Shoe Co. v. Washington, 326 U.S. 310, 317, 66 S.Ct. 154, 90 L.Ed. 95 (1945).
. In this state, the conception of a child during the course of a marriage creates a presumption of paternity. See § 19-4-105(1)(a), 6 CRS. (2003).