Specific versus General Jurisdiction for Corporations
==Ford v. Montana==
[https://www.supremecourt.gov/opinions/20pdf/19-368_febh.pdf FORD MOTOR CO. v. MONTANA EIGHTH JUDICIAL DISTRICT COURT ET AL.], CERTIORARI TO THE SUPREME COURT OF MONTANA No. 19–368. Argued October 7, 2020—Decided March 25, 2021*
Ford Motor Company is a global auto company, incorporated in Delaware and headquartered in Michigan. Ford markets, sells, and services its products across the United States and overseas. The company also encourages a resale market for its vehicles. In each of these two cases, a state court exercised jurisdiction over Ford in a products-liability suit stemming from a car accident that injured a resident in the State. The first suit alleged that a 1996 Ford Explorer had malfunctioned, killing Markkaya Gullett near her home in Montana. In the second suit, Adam Bandemer claimed that he was injured in a collision on a Minnesota road involving a defective 1994 Crown Victoria. Ford moved to dismiss both suits for lack of personal jurisdiction. It argued that each state court had jurisdiction only if the company’s conduct in the State had given rise to the plaintiff’s claims. And that causal link existed, according to Ford, only if the company had designed, manufactured, or sold in the State the particular vehicle involved in the accident. In neither suit could the plaintiff make that showing. The vehicles were designed and manufactured elsewhere, and the company had originally sold the cars at issue outside the forum States. Only later resales and relocations by consumers had brought the vehicles to Montana and Minnesota. Both States’ supreme courts rejected Ford’s argument. Each held that the company’s activities in the State had the needed connection to the plaintiff’s allegations that a defective Ford caused instate injury.
Held: The connection between the plaintiffs’ claims and Ford’s activities in the forum States is close enough to support specific jurisdiction.
My Thoughts
It shouldn't matter even if Ford doesn't make or sell a single car in Utah. Ford is negligent or malicious in Ohio. Its agent meets the particular victim in Iowa. But the harm occurs in Utah. That's where many or all of the witnesses are.
It shouldn't matter even if Ford doesn't make or sell a single car in Utah. Ford is negligent or malicious in Ohio. Its agent meets the particular victim in Iowa. But the harm occurs in Utah. That's where many or all of the witnesses are.
