Ford Motor Co. v. Mont. Eighth Judicial Dist. Court
443 P.3d 407, 2019 MT 115, 395 Mont. 478 (2019)
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Rule of Law:
A state court may exercise specific personal jurisdiction over a non-resident product manufacturer when the manufacturer purposefully avails itself of the privilege of doing business in the state, and the lawsuit relates to an in-state injury caused by the manufacturer's product, even if the specific product was not designed, manufactured, or first sold in that state.
Facts:
- Ford Motor Company (Ford) assembled a 1996 Ford Explorer in Kentucky.
- Ford sold this specific Explorer for the first time to a dealer in Washington.
- Over ten years later, the Explorer was resold and came to be owned by Markkaya Jean Gullett, a Montana resident.
- In 2015, while Gullett was driving the Explorer on an interstate in Montana, one of its tires suffered a tread/belt separation.
- The vehicle subsequently lost stability, rolled over, and crashed, resulting in Gullett's death at the scene.
- Ford is registered to do business in Montana, advertises extensively in the state, and maintains 36 dealerships that sell and service Ford vehicles, including Explorers.
Procedural Posture:
- Charles Lucero, on behalf of Markkaya Gullett's estate, sued Ford Motor Company in the Eighth Judicial District Court of Montana, a state trial court.
- Ford filed a motion to dismiss the case for lack of personal jurisdiction.
- The District Court denied Ford's motion to dismiss.
- Ford petitioned the Supreme Court of Montana for a writ of supervisory control, asking it to review and reverse the trial court's order.
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Issue:
Does Montana have specific personal jurisdiction over Ford regarding Lucero's design defect, failure to warn, and negligence claims when the vehicle accident occurred in Montana but the vehicle was not designed, manufactured, or first sold by Ford in Montana?
Opinions:
Majority - The Court (Unanimous)
Yes. A Montana court has specific personal jurisdiction over Ford because Ford's extensive business activities in the state create a sufficient connection between the forum, the defendant, and the litigation. The court's reasoning follows a two-part jurisdictional test. First, Ford's conduct falls under Montana's long-arm statute because the alleged tort (defective design and failure to warn) accrued in Montana where the injury-causing accident occurred. Second, exercising jurisdiction is constitutional and comports with due process. This conclusion is based on a three-pronged analysis: 1) Ford purposefully availed itself of the Montana market under the 'stream of commerce plus' theory by advertising, selling, and servicing vehicles through its 36 in-state dealerships. 2) The lawsuit 'relates to' Ford's forum-related activities because a nexus exists between the product (the Explorer) and Ford's in-state activities (selling and servicing Explorers), and it was reasonably foreseeable that a vehicle designed for travel would be used in Montana. 3) Exercising jurisdiction is reasonable, as Ford has not shown a compelling burden, and Montana has a strong interest in providing a forum for its residents injured by products actively marketed within its borders.
Analysis:
This decision broadens the scope of specific personal jurisdiction in products liability cases by adopting a 'relates to' standard that does not require a direct causal link between the defendant's in-state conduct and the specific product that caused the harm. By establishing that a manufacturer's systematic cultivation of a state's market is sufficient to create jurisdiction for an in-state injury, the court provides a pathway for plaintiffs to sue corporations in the forum where the injury occurred. This precedent challenges a more restrictive interpretation of specific jurisdiction that would focus narrowly on the specific product's chain of distribution, making it more difficult for national corporations to evade suit in states where they maintain a significant market presence but where the specific injury-causing product was first sold elsewhere.
