Gray v. Standard American Radiator & Standard Sanitary Corp.

Citation. 176 N.E.2d 761 (1961)

Brief Fact Summary.

Plaintiff sued Defendant for an injury caused by one of Defendant’s products under an Illinois statute that extended personal jurisdiction over nonresidents involved in a tort. Defendant moved to dismiss the case, arguing the statute violated due process.

Synopsis of Rule of Law.

A nonresident defendant not served with process within the forum state nevertheless is subject to personal jurisdiction in the forum state if the defendant had sufficient minimum contacts with the state and reasonable notification of the lawsuit.

Facts.

Phyllis Gray (Plaintiff) was injured by an exploding water heater in Illinois. She brought suit in Illinois against Titan Valve Manufacturing Company (Defendant), a company with no agents or business connections in Illinois, for negligently making the water heater’s safety valve. Defendant was served with process in Ohio. Personal jurisdiction over Defendant was established under an Illinois statute stating that a nonresident who commits a tortious act in Illinois was subject to personal jurisdiction in the state. Defendant brought a motion to dismiss, arguing that the statute violated due process.

Issue.

Does the Illinois statute extending personal jurisdiction over nonresident Defendant violate due process?

Held.

No, the Illinois statute does not violate due process and Illinois properly exercised personal jurisdiction over the Defendant. The opinion of the lower court is reversed.

Discussion.

First, the Court determined that the Defendant’s conduct did fall within the statute, because the statute extended personal jurisdiction over nonresidents connected to an injury occurring in Illinois. Here, although the product was made and sold outside of Illinois, an Illinois resident was injured by the product in Illinois. Next, the Court determined that the Illinois statute did not violate due process because Defendant did have sufficient minimal contacts with Illinois for personal jurisdiction to be proper. The use of the product in the ordinary course of commerce was a sufficient contact with Illinois, where Defendant’s product was often bought and used under the benefits and protections of Illinois law. Additionally, the Court supported litigation in Illinois on grounds of convenience, given that Plaintiff was a resident of Illinois, injured in Illinois, and witnesses were all in Illinois.