Plaintiff sued Defendant for product liability. Defendant filed a cross-complaint against Co-Defendant.
A finding of minimum contacts, sufficient to establish personal jurisdiction, is established by the defendant purposefully directing actions towards the forum state.
Gary Zurcher (Plaintiff) and his wife were injured while riding his motorcycle. Arguing that the accident occurred because of an exploding tire, Plaintiff sued Cheng Shin Rubber Industrial Co. (Defendant), a Taiwanese company that made the inner tube of the tire. Defendant filed a cross-claim against Asahi Metal Industry (Co-Defendant), a Japanese company that made the valve assembly of the tire.
Is mere awareness that a product would reach a forum state enough to establish minimum contacts sufficient for personal jurisdiction?
No, mere awareness is not enough and exercising personal jurisdiction over the Co-Defendant is a violation of due process. The lower court’s opinion is reversed and remanded.
Justice Brennan agreed that exercising personal jurisdiction over the Co-Defendant would violate fair play and substantial justice. However, he did not agree with the Court’s conclusion that mere awareness that a product will enter a forum state is not enough to establish minimum contacts.
Justice Stevens argued that it was not necessary to determine whether Co-Defendant had minimum contacts. Justice Stevens also argued that the Court should have considered the high volume of the Co-Defendant’s parts reaching California as purposeful business.
The Court determined that the Co-Defendant had not purposefully directed any actions towards the forum state sufficient to establish minimum contact with the state. Co-Defendant does not do business in California, did not advertise in California, and did not participate in the process that lead to the distribution of the tire in California.