ProfessorBrittany L. Raposa
CaseCast™ – "What you need to know"
Brief Fact Summary. A person injured in a motorcycle accident sued the manufacturer of the motorcycle’s tire, who then filed a cross-complaint against the manufacturer of one part of the tire.
Synopsis of Rule of Law. The substantial connection between the Defendant and the forum state necessary for a finding of minimum contacts must come about by an action of the Defendant purposefully directed toward the forum state.
Majority Opinion Footnotes* We have no occasion here to determine whether Congress could, consistent with the Due Process Clause of the Fifth Amendment, authorize federal court personal jurisdiction over alien defendants based on the aggregate of national contacts, rather than on the contacts between the defendant and the State in which the federal court sits.View Full Point of Law
Issue. Whether the mere awareness of the part of a foreign Defendant that the components it manufactured, sold, and delivered outside the United States would reach the forum state in the stream of commerce constitutes sufficient minimum contacts rendering jurisdiction appropriate.
Held. No. The Supreme Court of the United States reversed the Supreme Court of California’s ruling upholding jurisdiction. Due Process requires more than that the Defendant was aware of its product’s entry into the forum state through the stream of commerce in order for the state to exercise jurisdiction over the Defendant. The substantial connection between the Defendant and the forum state necessary for a finding of minimum contacts must come about by an action of the Defendant purposefully directed toward the forum state. The placement of a product in the stream of commerce, without more, is not an act of the Defendant purposefully directed toward the forum state. Concurrence. Justice Brennan concurred, in which he was joined by Justices White, Marshall, and Blackmun. Justice Brennan disagreed with the stream of commerce theory, as well as the court’s conclusion that Asahi did not purposely avail itself of the California market. However, despite finding sufficient minimum contacts, Justice Brennan still found jurisdiction improper because fair play and substantial justice would not be achieved. Justice Stevens also concurred, in which he was joined by Justices White and Blackmun. Specifically, he found that minimum contacts are not always necessary for a state court to invoke jurisdiction.
Discussion. In analyzing whether jurisdiction would offend traditional notions of fair play and substantial justice, the court noted that the burden on the Defendant to defend the suit would be severe. Moreover, the court noticed that California’s interest in the suit is slight, since the Plaintiff is not a California resident.