Summary
The Supreme Court held that Montana and Minnesota courts could exercise specific personal jurisdiction over Ford Motor Company in products-liability suits involving accidents and injuries occurring in those States. Ford’s extensive activities marketing, selling, and servicing the relevant vehicle models in the forum States sufficiently related to the claims, even though the particular vehicles were designed, manufactured, and initially sold elsewhere. The Court affirmed the judgments of the Montana and Minnesota Supreme Courts.
Topics
Practice areas
Questions Presented
- Whether the Due Process Clause permits a state court to exercise specific personal jurisdiction over a nonresident corporation when the plaintiff's claims arise from an in-state injury caused by a product the corporation extensively marketed, sold, and serviced in the forum state, even though the particular product was designed, manufactured, and first sold elsewhere.
Holdings
- Yes. The connection between the plaintiffs' claims and Ford's activities in the forum States is close enough to support specific jurisdiction. When a company serves a market for a product in a State and that product causes injury in the State to one of its residents, the State's courts may entertain the resulting suit.
Key quotations
“When a company like Ford serves a market for a product in a State and that product causes injury in the State to one of its residents, the State’s courts may entertain the resulting suit.” (Slip Op. at 2)
“The first half of that standard asks about causation; but the back half, after the “or,” contemplates that some relationships will support jurisdiction without a causal showing.” (Slip Op. at 9)
“Ford had systematically served a market in Montana and Minnesota for the very vehicles that the plaintiffs allege malfunctioned and injured them in those States.” (Slip Op. at 12)
Factual background
Ford is a global auto company incorporated in Delaware and headquartered in Michigan, but it extensively markets, sells, and services vehicles in every state. Markkaya Gullett was killed in Montana when the tread separated from a rear tire on her 1996 Ford Explorer, leading to a rollover; her estate sued Ford in Montana state court. Adam Bandemer was severely injured in Minnesota when the airbag in a 1994 Ford Crown Victoria failed to deploy during a collision; he sued Ford in Minnesota state court. Ford moved to dismiss both suits for lack of personal jurisdiction, arguing that the particular vehicles were designed, manufactured, and first sold outside the forum states. The Montana and Minnesota Supreme Courts both rejected that argument.
Procedural history
Ford moved to dismiss products-liability suits for lack of personal jurisdiction in Montana and Minnesota. The state trial courts denied the motions; the Montana Supreme Court and Minnesota Supreme Court affirmed. The U.S. Supreme Court granted certiorari and affirmed the judgments.