Ford Motor Co. v. Mont. Eighth Judicial Dist. Court
443 P.3d 407, 395 Mont. 478, 2019 MT 115 (2019)
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Rule of Law:
A state court may exercise specific personal jurisdiction over a nonresident defendant in a product liability action where the injury occurred in the forum state, even if the specific product was designed, manufactured, and first sold elsewhere, provided the defendant cultivates a market for that type of product in the forum state.
Facts:
- Markkaya Jean Gullett, a Montana resident, owned and drove a 1996 Ford Explorer.
- Ford Motor Company assembled this specific Explorer in Kentucky.
- Ford sold the Explorer for the first time to a dealership in the state of Washington.
- Over ten years after its first sale, the Explorer was resold and registered in Montana.
- In 2015, while Gullett was driving the Explorer on an interstate highway in Montana, one of its tires suffered a tread/belt separation.
- The vehicle lost stability, rolled into a ditch, and came to rest upside down, resulting in Gullett's death at the scene.
Procedural Posture:
- Charles Lucero, on behalf of Markkaya Jean Gullett's estate, filed suit against Ford Motor Company in the Eighth Judicial District Court of Montana, a state trial court.
- Ford filed a motion to dismiss the lawsuit 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 to review the trial court's order denying its motion.
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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 - Unspecified
Yes. A Montana court may exercise specific personal jurisdiction over Ford because the lawsuit relates to Ford's extensive activities in the state. The court applied a two-step analysis. First, jurisdiction is proper under Montana's long-arm statute because the tortious injury occurred in Montana. Second, exercising jurisdiction is constitutional and comports with due process. The court found that Ford purposefully availed itself of the Montana market under the 'stream of commerce plus' theory by advertising, selling vehicles (including Explorers), operating 36 dealerships, and providing services within the state. The court then held that the plaintiff's claims 'relate to' Ford's forum activities because a nexus exists between the product (the Explorer) and Ford's in-state business of selling and servicing vehicles, and it was reasonably foreseeable that a vehicle built for travel would be used in Montana. Finally, the court concluded that exercising jurisdiction is reasonable, as Montana has a strong interest in adjudicating a dispute involving a resident's death on its roadways, and Ford failed to show a compelling burden in defending the suit there.
Analysis:
This decision broadens the 'arises out of or relates to' prong of the specific personal jurisdiction analysis for product liability cases involving mobile goods. By not requiring a direct causal link between the defendant's in-state contacts and the specific product that caused the harm, the court established a more flexible standard. It focuses on the defendant's overall efforts to serve a market for the same type of product in the forum state. This ruling strengthens the ability of plaintiffs to sue large, national corporations in the forum where the injury occurred, contributing to a circuit split on the issue that would eventually be resolved by the U.S. Supreme Court.
