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Ford Motor Co. v. Montana Eighth Judicial District Court

Supreme Court of the United States · 2021 · Civil Procedure

Civil Procedurepersonal jurisdictionspecific jurisdictionarise out of or relate tostream of commercedue processminimum contactsspecific jurisdiction

Facts

Ford is incorporated in Delaware and headquartered in Michigan, but it extensively markets, sells, and services vehicles nationwide, including in Montana and Minnesota. In Montana, a resident died in an accident involving a 1996 Ford Explorer; in Minnesota, a resident suffered serious brain injury in an accident involving a 1994 Ford Crown Victoria. Ford argued that jurisdiction was lacking because the particular vehicles involved were designed and manufactured outside the forum states and were first sold outside those states before later resales and relocations brought them into Montana and Minnesota. At the same time, Ford actively advertised, sold, and serviced the same vehicle models in both forum states.

Issue

Whether a state may exercise specific personal jurisdiction over Ford in products-liability suits arising from in-state accidents involving forum residents when Ford extensively marketed, sold, and serviced the same vehicle models in the forum, but the particular vehicles at issue were first sold, designed, and manufactured elsewhere. More specifically, does due process require a strict causal link between the defendant's forum contacts and the plaintiff's claims?

Rule

Under the Due Process Clause, specific jurisdiction exists when the defendant has purposefully availed itself of the privilege of conducting activities in the forum state and the plaintiff's claims arise out of or relate to the defendant's contacts with the forum. The phrase "arise out of or relate to" does not require only a strict causal relationship; a strong relationship among the defendant, the forum, and the litigation can suffice when the defendant extensively serves a market in the forum for the very product alleged to have malfunctioned there.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Prairie Ridge Appliances, incorporated in Delaware and headquartered in Ohio, heavily advertises, sells, and services its "Summit" space heaters throughout Colorado through a network of dealers and repair centers. A Denver resident was injured in Denver when a used Summit heater allegedly malfunctioned, but that particular heater had first been sold years earlier in Utah before being resold into Colorado.

If the resident sues Prairie Ridge Appliances in Colorado state court for products liability, is specific personal jurisdiction most likely proper?

Explanation. Specific jurisdiction requires purposeful availment plus a claim that arises out of or relates to the defendant’s forum contacts. The majority rejected a strict causation-only rule. When a company extensively advertises, sells, and services the very product in the forum, and a forum resident is injured there by that product, the suit sufficiently relates to the company’s forum activities even if the particular item was first sold outside the state. (Derived from Ford Motor Co. v. Montana Eighth Judicial District Court (2021).)