Ford Motor Co. v. Montana Eighth Judicial Dist.
592 U. S. ____ (2021) (2021)
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Rule of Law:
A state court can exercise specific personal jurisdiction over a defendant corporation in a lawsuit arising from a product that the company markets, sells, and services in the forum state, even if the particular product that caused the in-state injury was originally sold in a different state.
Facts:
- Ford Motor Company is a global automaker incorporated in Delaware and headquartered in Michigan.
- Ford extensively markets, sells, and services its vehicles, including the Explorer and Crown Victoria models, throughout the United States, including in Montana and Minnesota.
- Ford actively encourages a resale market for its vehicles through its dealership network and provides original parts and repair services nationwide.
- In Montana, Markkaya Gullett was killed when the tread on a tire of her 1996 Ford Explorer separated, causing a rollover accident.
- The specific Explorer involved in Gullett's accident was designed in Michigan, manufactured in Kentucky, and originally sold by Ford in Washington.
- In Minnesota, Adam Bandemer suffered a serious brain injury in a collision when the airbag in a 1994 Crown Victoria failed to deploy.
- 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 were brought into Montana and Minnesota, respectively, through subsequent resales and relocations by consumers.
Procedural Posture:
- The representative of Markkaya Gullett's estate sued Ford Motor Co. in a Montana state trial court.
- Adam Bandemer sued Ford Motor Co. 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 to the Supreme Court of Montana, which affirmed the trial court's decision.
- Ford appealed to the Supreme Court of Minnesota, which also affirmed the trial court's decision.
- The U.S. Supreme Court granted certiorari to review both decisions.
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Issue:
Does a state court have specific personal jurisdiction over a corporate defendant in a product liability suit where the defendant has extensive contacts with the forum state (e.g., marketing, sales, service), the plaintiff's injury occurred in the forum state, but the specific product that caused the injury was not designed, manufactured, or originally sold by the defendant in that forum state?
Opinions:
Majority - Justice Kagan
Yes. A state court has specific personal jurisdiction when there is a strong relationship among the defendant, the forum, and the litigation. The legal standard for specific jurisdiction requires that a plaintiff's claims 'must 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 claim. Because Ford systematically served the markets in Montana and Minnesota for the very vehicle models that allegedly malfunctioned and injured residents in those states, a sufficient relationship exists. Ford purposefully availed itself of the states' markets through advertising, sales, and service, creating a reciprocal obligation to defend suits there when its products cause in-state harm. This case is distinct from Bristol-Myers Squibb, where the non-resident plaintiffs had no connection to the forum state, as the plaintiffs here are residents who were injured in their home states.
Concurring - Justice Alito
Yes. The court reached the correct outcome based on existing precedent without needing to create a new gloss on the law. Instead of separating 'arise out of' and 'relate to' into two distinct tests, the connection can be seen as causal in a broad sense. It is reasonable to infer that Ford's extensive marketing and service activities in Minnesota and Montana were a but-for cause of these specific vehicles being on the roads in those states. The majority's creation of a separate 'relate to' category risks needless confusion, as 'relate to' is a potentially boundless concept.
Concurring - Justice Gorsuch
Yes. Ford is subject to jurisdiction, but the Court's entire framework for personal jurisdiction under International Shoe is increasingly unworkable, especially for global corporations. The majority's new 'affiliation' test based on the phrase 'relate to' is vague and will create more confusion and litigation. The historical basis for jurisdiction, which focused on a defendant's presence or consent, would more simply and directly establish jurisdiction here, as Ford clearly entered Montana and Minnesota to do business. Corporations should not receive special jurisdictional protections that are not afforded to individuals.
Analysis:
This decision clarifies that the 'arise out of or relate to' standard for specific personal jurisdiction does not require strict but-for causation between the defendant's forum contacts and the plaintiff's injury. By emphasizing the 'relate to' prong, the Court makes it more difficult for large, national corporations to evade jurisdiction in states where they cultivate a market, even if the specific product item was sold elsewhere. The ruling solidifies the principle of reciprocity: a company that enjoys the benefits of a state's laws and markets must also accept the burden of defending suits there for in-state injuries caused by its products. This precedent will significantly impact product liability litigation against manufacturers with nationwide distribution networks.
