March 25, 2021
On March 25, 2021, the U.S. Supreme Court expanded the test established for personal jurisdiction by holding that a causal link to the cause of action is not necessary to establish specific jurisdiction over a non-resident defendant. Ford Motor Co. v. Montana Eighth Judicial District Court, et al. 592 U.S. _____ (2021). Instead, the Court focused its analysis on the “or relate” portion of the “arise out of or relate to the defendant’s contacts” standard established in Burger King Corp. v. Rudzewicz. The Court emphasized the Burger King standard contemplates that some relationships will support jurisdiction without a causal showing. In doing so, the Court held that Ford Motor Company could be sued in both Montana and Minnesota over injuries sustained from car accidents that occurred in those states, even though the particular Ford vehicles involved in the accidents were not manufactured or originally sold in either state. In support of its holding, the Court noted that Ford regularly markets, advertises, services and sells Ford vehicles (including the particular vehicles involved in both accidents) in Montana and Minnesota, and thus there was a strong relationship among the defendant, forum and litigation. The Court further distinguished the case from Bristol-Myers Squibb v. Superior Court by holding that the claims brought in that case were by non-resident plaintiffs who never purchased, used or were harmed by the products in the forum State. However, in these cases, both plaintiffs were residents who used the defective product and were injured in the forum State.
Please see attached: Personal Jurisdiction Opinion