Despite the history of jurisprudence relating to specific personal jurisdiction, the Supreme Court is still trying to figure out the limits of due process. So, here are some cases about specific personal jurisdiction.
Walden v. Fiore
134 S.Ct. 1115
Case was dismissed for lack of Specific Personal Jurisdiction in the district court. The circuit court reversed and the Supreme Court granted review.
Question
Is the defendant’s conduct with the plaintiffs in Nevada enough to establish SPJ?
Rule
The defendant’s suit related conduct must create a substantial connection with the forum state.
- Contact comes from the defendant’s actions
- Contact must be with the forum state, not just the plaintiff in the forum state.
Holding
There is insufficient evidence that the conduct was directed towards the forums state. Therefore, reversed and dismissed.
Facts
Plaintiff was traveling back to Nevada from out of country. They had a layover in Georgia where they were stopped by police officers and a lot of money was confiscated (believing it to be drug money). Once in Nevada, and the money had not yet been returned, and an affidavit was created in an attempt for the government to maintain the money, the plaintiffs filed suit in Nevada.
They had several fourth amendment claims, but we are focused on SPJ. There, the plaintiffs said that the affidavit should be enough to establish a contact because the defendant knew they were going back to Nevada.
Analysis
The court disagrees with the circuit court that the affidavit was enough to establish a sufficient minimum contact. To find SPJ, there needs to be sufficient evidence that the contact comes from the defendant’s actions and the contact is specifically tied to the forum state.
Here, although the defendant knew the defendant was returning to Nevada, that is not sufficient to establish a contact with the forum state. The actions of the defendant were tied specifically to the plaintiff, not the state. For example, if the plaintiff was in California or Mississippi, there would have been no other contact with the state of Nevada. Therefore, there is no SPJ.
Takeaways
Here, our biggest takeaway is that the claim must come from the actions of the defendant ties with the forum state and that the plaintiff’s connection to the forum state and the defendant is not sufficient to find SPJ.
Additional Notes
This presented a question that was left unopened from previous cases. “If the defendant is aware that their conduct will have effects in another jurisdiction, is that enough to establish personal jurisdiction? No” Why was this an open question? Because previous cases related to the tort of defamation, the tort was committed in California (new tort every time and every place the defamatory article is read). The difference here was that the tort was committed in Georgia. Therefore, because the only connection the defendant had to Nevada was the plaintiff (no conduct directed at the forum state), there can be no specific personal jurisdiction.
There are two different things here
- Where the bad conduct occurred
- Where the injury is felt
We care about where the conduct occurred.
Bristol Myers-Squibb Co. v. Superior Court of California
137 S.Ct. 1773
Bristol Myers-Squibb Co. is the defendant. Trial court found that there was general jurisdiction, changed that opinion to saying there was specific jurisdiction. Supreme Court now reviews.
Question
Can out of state defendants with similar claims to residents file suit along with those in-state residents?
Rule
The plaintiff’s claim needs to arise out of the defendant’s conduct with the forum state.
Holding
The out of state residents do not have specific personal jurisdiction.
Facts
Defendant is a pharmisutical company that created a drug in New York and New Jersey but sold it all over the United States. The plaintiffs here are over 600 individuals arising from 34 different states (86 come from California). Each plaintiff claims to have suffered harm from the drug and claims that jurisdiction can be found because of the several marketing campaigns for the drug.
Analysis
There is no specific personal jurisdiction for the non-residents here. Although the claims are all similar, the lack a proper forum state. The California plaintiffs can use California as their jurisdiction because their claim arose out of California due to the conduct of the defendant in that state. Likewise the other defendants would have claims in their home state. However, because their claim did not arise out of the conduct of the defendant in California, they have no jurisdiction.
Takeaways
For a plaintiff to find specific personal jurisdiction against a defendant, their claim needs to arise out of the issue with the forum state.
Additional Notes
Here, the plaintiffs purchased the product and were injured by it in another State (not California). Therefore, their injury was not related to the conduct of the defendant towards California (despite having similar situations).
Ford Motor Co. v. Montana Eighth District Court
141 S.Ct. 1017
Ford Motor Co. is the defendant.
Question
Does specific personal jurisdiction have to be causal connection with the forum state?
Rule
The plaintiff’s claim must “arise out of or relate to the defendant’s contacts with the forum.”
Holding
Here, the defendants have purposefully availed themselves to the forum states enough to find Specific Personal Jurisdiction.
Facts
Ford has a primary place of business in Michigan and incorporated in Delaware. The vehicles in question were manufactured in Kentucky and Canada and designed in Michigan. Finally, these vehicles were sold in Washington and North Dakota.
There are two plaintiffs here, each resulting from a separate accident. One party had purchased the vehicle in another state before crashing in their place of residence (Montana) and the other from another place of residence (Minnesota).
Ford advertises extensively in both of these states, services vehicles here, and runs many dealerships. So, is there specific personal jurisdiction in Montana and Minnesota?
Ford argues that there is no SPJ. Why? Because the vehicles were not purchased where the accidents occurred.
Analysis
First, the court refuted the “arise out of” argument by Ford. Although that is a valid argument, the court extends the rule to “or relate to” the defendant’s contacts with the forum. Therefore, the question is, “do the defendant’s contacts relate enough to the claim at hand? The court responds by saying yes. Because Ford had purposefully availed themselves to this forum state, the plaintiffs could were encouraged to purchase Ford vehicles. Thus, not only did Ford target the forum state with advertisements, the plaintiffs were also targeted consumers. Any claim that arose from them in that state would find SPJ.
Takeaways
This is another case where we are looking at the phrase “related to”. The key difference here is that the plaintiff was injured in the forum state.
Additional Notes
Specific personal jurisdiction is the most litigated feature of civil procedure.
The vast majority of questions deal with the words “arise from” instead of “relate to.” However, Ford discusses how we can analyze the words “relate to.” Related to means that the contacts are indirect but direct enough to subject the defendant to SPJ.
Disclaimer
The content contained in this article may contain inaccuracies and is not intended to reflect the opinions, views, beliefs, or practices of any academic professor or publication. Instead, this content is a reflection on the author’s understanding of the law and legal practices.
