Civil Procedure—Personal Jurisdiction/Product Liability
Ford Motor Co. v. Montana, No. 19-368 (March 25, 2021) (J. Kagan) https://www.supremecourt.gov/opinions/20pdf/19-368_febh.pdf
RESIDENTS OF STATE WHERE ACCIDENT OCCURRED HAVE PERSONAL JURISDICTION IN THAT STATE OVER FORD MOTOR CO. WHICH DOES SUBSTANTIAL BUSINESS IN THE STATE
In these two cases plaintiffs brought injury and wrongful death product liability claims against Ford Motor Company concerning a 1996 Ford Explorer and a 1994 Crown Victoria. Suit was filed in Montana and Minnesota, respectively both where the plaintiffs reside and where the accident causing the death and injury occurred. Ford moved to dismiss for lack of personal jurisdiction claiming the state courts would only have jurisdiction over Ford if Ford's conduct in the state caused plaintiffs' injury. Because Ford did not design or manufacture the vehicles in question in the forum states and because the vehicles in question were not purchased in the forum state, Ford argues there is no personal jurisdiction. The Montana Supreme Court, the Minnesota Supreme Court and the United States Supreme Court, all rejected Ford's position. Ford is a global auto company which markets, sells, services and promotes a resale market of its cars and trucks throughout the United States and abroad.
The Fourteenth Amendment to the U.S. Constitution's Due Process Clause defines when a state court can exercise jurisdiction over a defendant. General jurisdiction applies where the defendant “is at home” in the State—where it is incorporated or its principal place of business. This case involved specific jurisdiction. Specific jurisdiction applies when the defendant's relationship to the state may not be as strong as in general jurisdiction, but where nonetheless the defendant has performed “some act by which it purposefully avails itself of he privilege of conducting activities within the forum State.”
Ford had systematically served a market in Montana and Minnesota for the very vehicles that the plaintiffs allege malfunctioned
and injured them in those States. So there is a strong “relationship among the defendant, the forum, and the litigation”—the “essential
foundation” of specific jurisdiction. . . . Ford fairly, as this Court's precedents explain. In conducting so much business in Montana
and Minnesota, Ford “enjoys the benefits and protection of [their] laws”—the enforcement of contracts, the defense of property,
the resulting formation of effective markets. International Shoe, 326 U. S., at 319. All that assistance to Ford's in-state business
creates reciprocal obligations—most relevant here, that the car models Ford so extensively markets in Montana and Minnesota be safe
for their citizens to use there. Thus our repeated conclusion: A state court's enforcement of that commitment, enmeshed as it
is with Ford's government-protected in-state business, can “hardly be said to be undue. . . . . Finally, principles of “interstate federalism”
support jurisdiction over these suits in Montana and Minnesota. Id., at 293. Those States have significant interests at stake—“providing
[their] residents with a convenient forum for re-dressing injuries inflicted by out-of-state actors,” as well as enforcing their own safety regulations.