A college student from State A hit another car driven by a resident from State B when the college student was traveling through State B. The State B driver brought an action in State B state court against the State A college student, who has limited financial resources. The college student filed a motion to dismiss, claiming the State B court lacks personal jurisdiction.

Limited financial resources to defend the action

Explanation:

The college student can state the inconvenience and the financial pressure the motion can result in because of the nature of the incident. The student does not have the financial resources to defend himself in State B. This also does not comply with the "traditional notions of fair play and substantial justice" given that the student will not be able to defend his actions. Another argument claiming lack of personal jurisdiction will be that the constitutional minimum contacts test has not been met. The fair play and fair justice argument will be based on financial limitations of the student. However, it must be kept in mind that in order for this argument to be string, the student will need to provide proof of severe inconvenience and financial pressure resulting from the motion.