United States Supreme Court reaffirms that International Shoe remains the canonical decision in the area of personal jurisdiction in Ford Motor Co. v. Montana Eighth Judicial District Court
In the recent decision Ford Motor Co. v. Montana Eighth Judicial District Court, the United States Supreme Court addressed personal jurisdiction over companies doing business nationwide and reaffirmed that International Shoe remains the canonical decision in the area of personal jurisdiction.
This case stemmed from two separate motor vehicle accidents in Montana and Minnesota, respectively. Each accident was caused by defective Ford motor vehicle parts. Each individual motorist filed suit against Ford and alleged, inter alia, products liability, failure to warn, and negligence. Each plaintiff argued that specific jurisdiction existed because a person may have made the decision to purchase the vehicle because of Ford’s direct contacts with the forum state—such as advertisements on local media. Ford filed motions to dismiss in both cases and argued that, because it had not designed, manufactured, or sold the particular vehicles in the forum states, it did not have sufficient minimum contacts in either Minnesota or Montana and, thus, the state district courts lacked specific personal jurisdiction. Both the Montana and Minnesota Supreme Courts rejected this argument and held that Ford had sufficient minimum contacts with each forum because it carried out pervasive, targeted, sales, and marketing, operations in both states.
On appeal, the United States Supreme Court created a distinction between two categories of specific jurisdiction. The majority opinion concluded that plaintiffs could demonstrate specific jurisdiction by showing that their claim either arose out of—or that it merely related to—Ford’s activities in the state. While the Court ultimately created this distinction, it explained that the plaintiffs’ allegations were sufficient to support a finding that their claims directly arose from Ford’s pervasive activities in Montana and Minnesota. So, this does little to change the already existing landscape of personal jurisdiction because a defendant still must have purposefully availed itself of the privileges of conducting activity in the forum state, and it still cannot be sued in a forum if its activities there are isolated or sporadic. Despite what some plaintiff-side counsel are already arguing, this case does not revolutionize or even dramatically change the requirements for personal jurisdiction. However, it does expand very slightly the concept of personal jurisdiction in ways which are relevant to insurers, trucking companies, and any other businesses that have regular and directed contact to multiple states.