J. McIntyre Machinery, Ltd. v. Nicastro

Brief Fact Summary.

Nicastro sustained a serious injury to his hand while using a metal shearing machine manufactured by J. McIntyre. The injury occurred in New Jersey; the machine was manufactured in England by J. McIntyre. J. McIntyre had not marketed goods in New Jersey or shipped any goods into the state. The New Jersey Supreme Court held that J. McIntyre was subject to the jurisdiction of  the New Jersey courts.

Synopsis of Rule of Law.

The authority to subject a defendant to a court’s jurisdiction depends upon the defendant’s “purposeful availment” of the forum, revealing an intention to invoke or benefit from the laws of a forum.

Facts.

Nicastro brought a products liability action against J. McIntyre after he sustained a serious injury to his hand while using a metal shearing machine manufactured by J. McIntyre. Nicastro’s injury occurred in New Jersey. The metal shearing machine was manufactured in England by J. McIntyre. An independent company sold J. McIntyre’s machines in the United States. J. McIntyre’s officials attended conventions in the United States, but never in New Jersey. No more than four of J. McIntyre’s machines ended up in New Jersey. J. McIntyre had not marketed goods in New Jersey or shipped any goods into the state. The New Jersey Supreme Court held that J. McIntyre was subject to the jurisdiction of  the New Jersey courts.

Issue.

Was a British manufacturer of scrap metal machines that did not advertise in, send goods to, or otherwise “target” New Jersey subject to the jurisdiction of the New Jersey state courts?

Held.

No. A plurality of the court held that a British manufacturer of scrap metal machines that did not advertise in, send goods to, or otherwise “target” New Jersey was not subject to the jurisdiction of the New Jersey state courts.

Dissent.

Justice Ginsburg

The dissent argued that jurisdiction in New Jersey was proper given McIntyre’s activities and desire to reach customers throughout the United States. In addition, the dissent stated that the plurality’s decision took a “giant step” away from previous decisions refining the minimum contacts analysis.

Concurrence.

Justice Breyer

Justice Breyer concurred in the plurality’s result, denying the New Jersey court’s jurisdiction over McIntyre, but not the plurality’s reasoning. Considering the increasing globalization at the time, and its impact on the scope of personal jurisdiction, he would reject the adoption of a new rule regarding jurisdiction without greater consideration of the relevant modern commercial circumstances.

Discussion.

The New Jersey court’s exercise of jurisdiction over J. McIntyre would violate due process since J. McIntyre did not engage in activities in New Jersey sufficient to indicate an intent to invoke the protections of, or benefit from application of, its laws. The general rule that a defendant must purposefully avail itself of the privilege of conducting business activities within the state to be subject to the exercise of its judicial power applied to preclude the jurisdiction of the New Jersey courts.