J. McIntyre Machinery, Ltd v. Nicastro

Brief Fact Summary.

An England based manufacturer sold products in the U.S. market through an Ohio based company and had its product resold to a consumer in New Jersey. A consumer gets injured using the manufacturer’s product and sued in a New Jersey court.

Synopsis of Rule of Law.

In order for personal jurisdiction to be proper the defendant must purposefully avail itself of the privilege of conducting activities within the forum state and therefore having the benefit and protection of its laws.

Facts.

Defendant J.Mcintyre, an English machine manufacturing company, hires an American based distributor to sell its machinery across the United States. Plaintiff Nacastro loses 4 fingers using Defendant manufacturer’s machine and sues Defendant in a New Jersey court.

Issue.

For personal jurisdiction to be proper, must a defendant purposefully avail itself to the privilege of conducting activities in the forum state, therefore having the benefit and protection of its laws?

Held.

Yes, for personal jurisdiction to be proper a defendant must purposefully avail itself to the privilege of conducting activities in the forum state, therefore having the benefit and protection of its laws. Judgement of the New Jersey Supreme Court reversed.

Concurrence.

Justice Justice Breyer with Justice Alio concurring

Plaintiff Nicastro failed to show that jurisdiction over Defendant J.Mcintyre was proper.

Justice Justice Ginsburg with Justice Sotomayor and Justice Kagan dissenting

J.McIntyre had the intent to sell his machines in the U.S. Just because a distributor was used does not mean J.McIntyre as the manufacturer should be able to escape liability.

Discussion.

1. The defendant must have minimum contacts.
2. The defendant must purposefully avail itself “of the privilege of conducting activities within the forum state, thus invoking the benefits and protections of its laws.” Hanson v. Denckla, 357 U.S. 235 (1958).
3. Purposeful availment may be physical presence or domicile in the forum state or having a place of business in the forum state.
4. While the holding in Asahi does not make clear what the standard is for foreign corporations, the general theme is that jurisdiction depends on the defendant’s actions not their expectations
5. Defendant J. McIntyre did not engage in any action directed at New Jersey specifically, only to the U.S. generally.
6. Therefore personal jurisdiction in a New Jersey court is improper.