Feathers v. McLucas
21 A.D.2d 558, 1964 N.Y. App. Div. LEXIS 3218, 251 N.Y.S.2d 548 (1964)
Rule of Law:
A foreign manufacturer can be subjected to personal jurisdiction under a state's long-arm statute for a tortious act within the state if its out-of-state wrongful act (e.g., defective manufacturing) results in injury within the state, provided the manufacturer could reasonably foresee that its product, intended for interstate commerce, might have consequences in the forum state, thereby satisfying federal due process minimum contacts.
Facts:
- In 1956, Darby Corporation, incorporated in Kansas, manufactured a tank trailer at its plant in Kansas City under a contract with Butler Manufacturing Co.
- Butler Manufacturing Co. mounted the tank trailer on wheels and subsequently sold it to E. Brooke Matlack, Inc., a Pennsylvania corporation and licensed interstate carrier.
- The tank trailer was constructed for its ultimate consignee, E. Brooke Matlack, Inc., and was intended for use in interstate commerce, which Darby Corporation knew.
- On July 25, 1962, while E. Brooke Matlack, Inc.'s tank trailer, loaded with liquefied petroleum gas, was en route from Pennsylvania to Vermont via Berlin, New York, it allegedly ruptured and exploded on a public highway.
- Plaintiffs sustained injuries and damages as a result of the explosion.
- Plaintiffs assert liability against Darby Corporation upon the predicate that the tank was faultily designed and defectively fabricated.
Procedural Posture:
- Plaintiffs initiated a lawsuit, asserting liability against Darby Corporation and other defendants on theories of negligence and breach of warranty.
- Darby Corporation moved for an order setting aside the service of the summons and complaint and dismissing the complaint against it, arguing it was not amenable to the process of New York courts due to a lack of business activity or facilities in the state.
- Special Term (the trial court) granted Darby Corporation's motion to dismiss the complaint for lack of personal jurisdiction.
- Plaintiffs appealed Special Term's decision to the Appellate Division.
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Issue:
Does a state's long-arm statute, authorizing jurisdiction over a nonresident defendant for a tortious act committed within the state, encompass situations where a foreign corporation's alleged wrongful act (defective manufacturing) occurs outside the state but results in injury within the state, satisfying the requirements of federal due process?
Opinions:
Majority - Per Curiam
Yes, a state's long-arm statute authorizing jurisdiction over a nonresident defendant for a tortious act committed within the state does encompass situations where a foreign corporation's alleged wrongful act occurs outside the state but results in injury within the state, provided federal due process requirements are met. The court interpreted CPLR 302(a)(2), which authorizes judicial jurisdiction for causes of action arising from a tortious act within the state, to include foreign wrongful acts that have resulting forum consequences. The Legislature did not intend to separate out-of-state wrongful acts from in-state consequences when expanding in personam jurisdiction. The allegedly defective manufacture of the tank, an instrumentality dangerous to life if defective and intended for interstate commerce, constitutes a tortious act with forum consequences in New York. To satisfy federal due process, a nonresident defendant must have 'minimum contacts' such that maintaining the suit does not offend 'traditional notions of fair play and substantial justice' (citing International Shoe Co. v. Washington). The court found that Darby, knowing the tank was for an interstate carrier and intended for interstate commerce, could reasonably foresee that its acts, if wrongful, might have potential consequences in adjoining New York. The single-act statute (CPLR 302) merely codified this minimum contacts test. The inconvenience and expense of a trial in New York would not place an undue burden on interstate commerce. Therefore, personal jurisdiction over Darby Corporation was acquired.
Analysis:
This case significantly broadened the scope of New York's long-arm jurisdiction under CPLR 302(a)(2), interpreting 'tortious act within the state' to include situations where the injury occurs in New York, even if the manufacturing defect occurred elsewhere. It established that foreseeability of a product's presence and potential harm in the forum state, especially for products intended for interstate commerce, is crucial for establishing minimum contacts, aligning state law with federal due process standards articulated in International Shoe. This ruling facilitated product liability claims against out-of-state manufacturers and demonstrated a legislative and judicial intent to maximize personal jurisdiction within constitutional limits, making it easier for New York residents injured by defective products to sue the manufacturer in New York.
