Frye v. Smith

Summary

The Alabama Supreme Court reviewed the dismissal of claims against former General Motors executives for lack of personal jurisdiction arising from an allegedly defective 1998 Chevrolet Blazer. The court also considered the plaintiffs’ motion to supplement the appellate record with interrogatory answers. It affirmed both the denial of supplementation and the dismissal, concluding that the individual defendants lacked sufficient minimum contacts with Alabama.

Holdings

1. The trial court did not exceed its discretion by denying the plaintiffs' motion to supplement the appellate record because the interrogatory answers were not part of the evidence before the trial court when it ruled and, even as described by the plaintiffs, did not conflict with the defendants' affidavits or materially affect the jurisdictional analysis.
2. Alabama courts may not exercise specific personal jurisdiction over individual corporate officers merely because the corporation placed a product into the stream of commerce or because the officers held senior corporate positions. The plaintiff must show that each individual defendant personally engaged in activity purposefully directed toward or purposefully availing the defendant of conducting activities in Alabama.
3. General personal jurisdiction was unavailable because the individual defendants did not have continuous and systematic contacts with Alabama.

Questions Presented

1. Whether the trial court abused its discretion by denying the plaintiffs' motion to supplement the appellate record with the individual defendants' answers to interrogatories.
2. Whether Alabama courts could exercise specific or general personal jurisdiction over the former GM officers based on their corporate positions and GM's placement of the Blazer into the stream of commerce.

Disposition

affirmed