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J. McIntyre Machinery v. Nicastro

Supreme Court of the United States · 2011 · Civil Procedure

Civil Procedurepersonal jurisdictionstream of commercepurposeful availmentpluralitypersonal jurisdictionspecific jurisdictionminimum contacts

Facts

J. McIntyre Machinery, Ltd. was a British manufacturer of scrap-metal machines that sold its products in the United States through an independent American distributor. The New Jersey Supreme Court relied on three facts: the distributor sold and shipped one machine to a New Jersey customer, the British manufacturer wanted the distributor to sell its machines anywhere in America, and representatives of the manufacturer attended trade shows in several U.S. cities outside New Jersey. The record, as described by the New Jersey Supreme Court, showed no regular flow of sales in New Jersey and no special New Jersey-focused design, advertising, advice, or marketing. Nicastro bore the burden of establishing jurisdiction.

Issue

Whether New Jersey could constitutionally exercise personal jurisdiction over a British manufacturer when the record showed only a single machine sale into New Jersey through an independent U.S. distributor, general efforts to serve the U.S. market, and attendance at trade shows outside New Jersey. More specifically, the question was whether those facts established sufficient minimum contacts and purposeful availment of New Jersey.

Rule

Personal jurisdiction must rest on minimum contacts and purposeful availment focused on the relationship among the defendant, the forum, and the litigation. Under existing precedent, a single isolated sale in the forum, even when accompanied by general efforts to serve the U.S. market through a distributor, is not enough on this record absent a regular flow or regular course of sales into the forum or some additional forum-specific conduct showing a purposeful effort to serve that state.

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

Nordvik Tools, a Swedish manufacturer, sells industrial tile cutters to the United States only through Great Plains Equipment, an independent distributor based in Texas. Great Plains sells one cutter to a construction company in Newark, New Jersey, where an employee is injured using it. Nordvik has no New Jersey advertising, no New Jersey customers list, and no employees or service agents in New Jersey.

If the employee sues Nordvik in New Jersey state court, which is the best argument about specific personal jurisdiction?

Explanation. The controlling rule is that specific jurisdiction must rest on minimum contacts and purposeful availment focused on the defendant, the forum, and the litigation. A single isolated sale in the forum, even alongside a general desire to serve the U.S. market through an independent distributor, is not enough on this limited record absent a regular flow of sales into the state or some additional forum-specific conduct. (Derived from J. McIntyre Machinery v. Nicastro (2011).)