Bandemer v. Ford Motor Co.

Summary

The Minnesota Supreme Court considers whether Minnesota courts may exercise specific personal jurisdiction over Ford Motor Company in a products-liability action involving a Ford vehicle that crashed in Minnesota. The court holds that Ford's sales, advertising, marketing, data-collection, and other contacts with Minnesota sufficiently relate to the claims and that exercising jurisdiction comports with due process. The court affirms the court of appeals.

Holdings

1. Minnesota may exercise specific personal jurisdiction over Ford because Ford purposefully availed itself of Minnesota through substantial sales, advertising, marketing, data collection, and other contacts, and Bandemer's claims arose out of or related to those contacts.
2. Due process does not require that Ford's Minnesota contacts have caused Bandemer's claims; it is sufficient that the claims arise out of or relate to Ford's Minnesota contacts.
3. Exercising specific personal jurisdiction over Ford was consistent with fair play and substantial justice.

Questions Presented

1. Whether Minnesota may exercise specific personal jurisdiction over Ford when the particular vehicle involved in the accident was designed, manufactured, and originally sold outside Minnesota.
2. Whether due process requires a causal connection between Ford's Minnesota contacts and Bandemer's claims, or whether jurisdiction is proper when the claims arise out of or relate to those contacts.
3. Whether the exercise of specific personal jurisdiction over Ford comports with fair play and substantial justice.

Disposition

affirmed