Bristol-Meyers Squibb Co. v. Superior Court of California, San Francisco County

Brief Fact Summary.

Plaintiffs sued Defendant in California for injuries suffered by a drug manufactured and sold by Defendant. Defendant moved to quash the summons by the nonresident Plaintiffs, arguing that California lacked personal jurisdiction.

Synopsis of Rule of Law.

Consistent with the Due Process Clause, a state has specific jurisdiction over a claim when there is a sufficient affiliation between the forum state and the underlying controversy.

Facts.

86 California residents and 592 nonresidents (Plaintiffs) brought a suit in California against Bristol-Meyers Squibb (Defendant), a pharmaceutical company incorporated in Delaware and headquartered in New York. The Plaintiffs alleged that one of the drugs manufactured and sold by Defendant in California, Plavix, damaged their health. The drug was not designed, developed, or manufactured in California, nor was it bought or taken in California by the nonresidents. Defendant argued that under these facts California lacked personal jurisdiction and moved to quash the summons by the nonresidents.

Issue.

Does California have specific jurisdiction over the Defendant for claims alleged by the nonresident Plaintiffs?

Held.

No, California does not have specific jurisdiction over the nonresidents’ claims against the Defendant. The lower court’s opinion is reversed and remanded.

Dissent.

Justice Sotomayor

Justice Sotomayor argued that California did have specific jurisdiction over the claims because Defendant purposefully availed itself California markets and it would not be unreasonable to exercise personal jurisdiction based on the Defendant’s contact with the state. She also argued that this case would make it harder to plaintiffs from different states to aggregate claims against large corporations.

Discussion.

The Court rejected the California Supreme Court’s sliding scale approach as too general to comport with precedent. It concluded that California lacked specific jurisdiction over the nonresidents’ claims because there was no connection between the forum state and the claims alleged by the nonresident Plaintiffs against the Defendant. The nonresidents did not buy or consume the drug in California, harm was not suffered in California, and any connection Defendant had to California was not related to the nonresident Plaintiffs’ claims.