J. McIntyre Machinery, Ltd. v. Nicastro

Brief Fact Summary.

Plaintiff brought suit in New Jersey against Defendant, an English company that manufactured the metal-sheering machine that injured his hand. Defendant argued New Jersey did not have personal jurisdiction.

Synopsis of Rule of Law.

Consistent with due process, a defendant is subject to personal jurisdiction in a state where they have purposefully avails themselves of the benefits and protections of the state’s laws, demonstrated by the defendant’s conduct and contacts with the state.

Facts.

Robert Nicastro (Plaintiff) brought suit in New Jersey against J. McIntyre Machinery (Defendant), a company incorporated in England that manufactured the metal-sheering machine that injured his hand. The product was manufactured in English and sold to the U.S. through an independent company’s nationwide distribution system. Defendant argued the state did not have personal jurisdiction.

Issue.

Has the Defendant purposefully availed itself of the New Jersey marketplace by placing its product into a nationwide distribution system, such that personal jurisdiction would not violate due process?

Held.

No, the Defendant has not purposely availed itself of the New Jersey marketplace and New Jersey exercising personal jurisdiction in this case would violate due process. The New Jersey Supreme Court’s decision is reversed.

Dissent.

Justice Ginsburg

Justice Ginsburg argued that New Jersey did have personal jurisdiction over the Defendant because Defendant purposefully entered the United States market, making it likely their product would end up anywhere in the United States. She argued that the Court’s opinion would unjustly allow manufacturers to avoid liability by having independent distributors market their products, going against traditional notions of fair play and substantial justice.

Concurrence.

Justice Breyer

Justice Breyer supported the outcome of the case based on precedent that a single sale of a product does not create a sufficient connection to a state for purposes of personal jurisdiction. However, he worried about the broad applicability of the rule articulated by the Court given the likelihood of changes in modern commerce and communication.

Discussion.

The Court, in an attempt to clarify their decision in Asahi, shifted personal jurisdiction analysis away from whether or not a product had entered the stream of commerce to focus on the specific conduct and contacts of defendants within the state. Here, the Court concluded that the Defendant did not purposefully avail itself to New Jersey because it had no place of business, paid no taxes to, and did not advertise in New Jersey.