Ford Motor Co. v. Montana Eighth Judicial Dist.
592 U. S. ____ (2021) (2021)
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Rule of Law:
Specific personal jurisdiction exists over a defendant corporation for a resident's product liability claim when the company systematically serves a market in the forum state for the very type of product that allegedly caused the in-state injury, even if the particular product at issue was not first sold in that state.
Facts:
- Ford Motor Company, incorporated in Delaware and headquartered in Michigan, markets, sells, and services its vehicles across the United States, including in Montana and Minnesota.
- Markkaya Gullett, a Montana resident, was killed in Montana when her 1996 Ford Explorer crashed.
- The specific Ford Explorer involved in Gullett's accident was designed in Michigan, manufactured in Kentucky, and originally sold by Ford in Washington.
- Adam Bandemer, a Minnesota resident, was seriously injured in Minnesota when the airbag in a 1994 Crown Victoria failed to deploy during a collision.
- The specific Crown Victoria involved in Bandemer's accident was designed in Michigan, manufactured in Canada, and originally sold by Ford in North Dakota.
- Both vehicles ended up in Montana and Minnesota, respectively, through subsequent resales and relocations by consumers.
Procedural Posture:
- The representative of Markkaya Gullett’s estate sued Ford in a Montana state trial court.
- Adam Bandemer sued Ford in a Minnesota state trial court.
- In both cases, Ford filed a motion to dismiss for lack of personal jurisdiction.
- The trial courts in both Montana and Minnesota denied Ford’s motions.
- Ford appealed the denials to the respective state supreme courts.
- The Supreme Court of Montana and the Supreme Court of Minnesota both affirmed the trial courts' decisions, holding that jurisdiction was proper.
- The U.S. Supreme Court granted certiorari to hear both cases, which were consolidated.
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Issue:
Does a state court have specific personal jurisdiction over a defendant corporation for a resident's product liability claim when the company markets and sells that same type of product in the state, but the specific product causing the injury was designed, manufactured, and originally sold elsewhere?
Opinions:
Majority - Justice Kagan
Yes. A state court can exercise specific personal jurisdiction over a defendant when the plaintiff's claims 'arise out of or relate to' the defendant's contacts with the forum. The 'relate to' prong of this standard does not require a strict causal link showing the defendant's in-state conduct gave rise to the plaintiff's claim. Instead, jurisdiction is proper when a company systematically serves a market in a state for a product, and that product malfunctions and injures a resident in that state. Here, Ford extensively advertises, sells, and services Explorers and Crown Victorias in Montana and Minnesota, cultivating a market for the very vehicles that allegedly caused the plaintiffs' in-state injuries. This creates a strong relationship among the defendant, the forum, and the litigation, making the exercise of jurisdiction fair and reasonable, consistent with precedents like World-Wide Volkswagen.
Concurring - Justice Alito
Yes. The outcome is correct under existing precedent, but the majority's creation of a new, independent 'relate to' test is unnecessary and unwise. The phrase 'arise out of or relate to' should not be parsed like a statute, and these cases could be resolved by understanding causation in a 'broad sense.' It is reasonable to infer that Ford's extensive marketing, sales, and service activities in Minnesota and Montana were a but-for cause of these specific vehicles being on the road there. The majority's new test, which separates 'relate to' from causation, risks needless complications because its limits are undefined.
Concurring - Justice Gorsuch
Yes. The outcome is correct, but the entire framework of personal jurisdiction established in International Shoe is increasingly uncertain and ill-suited to the modern economy. The majority's new 'relate to' standard, focusing on an 'affiliation' or 'connection,' replaces a but-for causation test with a vague assortment of nouns that will create confusion and litigation. The historical basis for jurisdiction focused on a corporation's presence or consent, and the Court's modern jurisprudence struggles to express these old ideas in new words. While the outcome is correct because Ford clearly entered these jurisdictions to do business, the underlying legal framework needs re-examination.
Analysis:
This decision clarifies the 'arise out of or relate to' standard for specific personal jurisdiction, significantly impacting product liability litigation against national corporations. By rejecting the need for a strict causal link between a defendant's forum contacts and the plaintiff's injury, the Court expands the scope of the 'relate to' prong. The ruling makes it easier for plaintiffs to sue corporations in the state where they were injured by a product, provided the company has systematically cultivated a market for that type of product in the forum. This prevents companies from avoiding jurisdiction based on the fortuity of where a specific item was first sold and reinforces the state's interest in providing a forum for its injured residents.
