Bristol-Myers Squibb Co. v. Superior Court

Brief Fact Summary.

Plaintiffs sued Defendant in California state court, alleging that the pharmaceutical company’s drug Plavix had damaged their health. Defendant was incorporated in Delaware, headquartered in New York, and maintained substantial operations in both New York and New Jersey. Although it engaged in business activities in California and sold Plavix there, Defendant did not develop, manufacture, label, package, or work on the regulatory approval for Plavix in California. The nonresident Plaintiffs did not allege that they obtained Plavix from a California source, that they were injured by Plavix in California, or that they were treated for their injuries in California. The California Superior Court denied Defendant‘s motion to quash service of summons on the nonresidents’ claims for lack of personal jurisdiction, concluding that Defendant‘s extensive activities in the State gave the California courts general jurisdiction. The California Supreme Court ruled that the California court had no jurisdiction.

Synopsis of Rule of Law.

For a state court to assert specific jurisdiction, there must be an affiliation between the forum state and the specific claim at issue.

Facts.

Plaintiffs, most of whom were not California residents, sued Defendant in California state court, alleging that the pharmaceutical company’s drug Plavix had damaged their health. Defendant was incorporated in Delaware and headquartered in New York, and it maintained substantial operations in both New York and New Jersey. Although it engaged in business activities in California and sold Plavix there, Defendant did not develop, create a marketing strategy for, manufacture, label, package, or work on the regulatory approval for Plavix in the State. The nonresident Plaintiffs did not allege that they obtained Plavix from a California source, that they were injured by Plavix in California, or that they were treated for their injuries in California. The California Superior Court denied Defendant‘s motion to quash service of summons on the nonresidents’ claims for lack of personal jurisdiction, concluding that Defendant‘s extensive activities in the State gave the California courts general jurisdiction. The Supreme Court ruled that the California court had no jurisdiction.

Issue.

Did the state court have jurisdiction over the claims of non-residents?

Held.

No.

Dissent.

Justice Sotomayor

The majority’s holding would make it unnecessarily difficult for individual plaintiffs across different states to aggregate claims against a large corporate defendant that inflicts identical harms nationwide. It is not unfair to subject a national corporation to one single suit for damages that it incurred nationwide.

Discussion.

For a state court to assert specific jurisdiction, there must be an affiliation between the forum state and the specific claim at issue. It is not sufficient for the defendant to have other contacts with the forum state; the contacts must be related to the claim at issue. If the defendant’s conduct giving rise to the claim and the plaintiff’s injury both occur outside of the state, the court likely cannot assert specific jurisdiction. Further, the fact that the claims and injuries of resident plaintiffs are identical to those of nonresident plaintiffs is immaterial to the question of specific jurisdiction. In this case, the lower courts erred in finding that California state courts have specific jurisdiction over the nonresident plaintiffs’ claims. Although Defendant has many contacts with California, none of those contacts is affiliated with the nonresident plaintiffs’ claims. Defendant did not design, develop, or manufacture Plavix in California, and the nonresident plaintiffs did not buy or take Plavix in California. Thus, both the Defendant conduct giving rise to the claims and the nonresident plaintiffs’ injuries occurred outside of California. There is no affiliation between California and the nonresident plaintiffs’ claims. Accordingly, California courts do not have specific jurisdiction over the nonresidents’ claims. The judgment is reversed, and the case is remanded.