J. McIntyre Machinery, Ltd. v. Nicastro

Summary

The Supreme Court reversed the New Jersey Supreme Court's exercise of personal jurisdiction over a British manufacturer in a products-liability action. The plurality concluded that due process requires conduct purposefully directed at the forum State and that a general stream-of-commerce theory based on foreseeability is insufficient. Justice Breyer concurred in the judgment on narrower grounds, while Justice Ginsburg dissented.

Holdings

1. New Jersey lacked personal jurisdiction over J. McIntyre Machinery because the manufacturer did not engage in conduct purposefully directed at New Jersey, and the limited facts did not establish purposeful availment of the New Jersey market.
2. A nationwide distribution system and the foreseeability that a product may reach a State do not, standing alone, establish personal jurisdiction over a foreign manufacturer in that State.

Questions Presented

1. Whether New Jersey may exercise specific personal jurisdiction over a foreign manufacturer whose product entered New Jersey through an independent nationwide distributor and caused injury there.
2. Whether placing a product into the stream of commerce with knowledge that it might reach the forum is sufficient for personal jurisdiction without conduct purposefully directed at the forum State.