Friday, December 27, 2013

J. McIntyre Machinery, Ltd. v. Nicastro case brief

J. McIntyre Machinery, Ltd. v. Nicastro case brief summary
131 S.Ct. 2780 (2011)

Petitioner British manufacturer moved to dismiss respondent consumer's products-liability suit, arguing lack of personal jurisdiction. Under the "stream-of-commerce" doctrine, the Supreme Court of New Jersey held that the Fourteenth Amendment's Due Process Clause was not violated by the New Jersey court's exercise of jurisdiction. Certiorari was granted.


  • In products-liability cases, it was a defendant's purposeful availment that made jurisdiction consistent with traditional notions of fair play and substantial justice. 
  • The transmission of goods permitted the exercise of jurisdiction only where the defendant targeted the forum; generally, it was not enough that it might have predicted its goods would reach the forum State. 
  • The manufacturer directed marketing and sales efforts at the U.S., but the question was whether the New Jersey state court had the authority to exercise jurisdiction; thus, it was the manufacturer's purposeful contacts with New Jersey, not with the U.S., that alone were relevant. 
  • A distributor sold the products, the manufacturer's officials attended trade shows in several States but not in New Jersey, and up to four machines ended up in New Jersey. 
  • The manufacturer had no office in New Jersey; it neither paid taxes nor owned property there; and it neither advertised in, nor sent any employees to, the State. 
  • It did not have a single contact with New Jersey short of the product in question ending up in New Jersey. 
  • The Supreme Court of New Jersey's holding was error.

The Court reversed the Supreme Court of New Jersey's judgment finding personal jurisdiction over the manufacturer. 6-3 Decision; 1 Concurrence; 1 Dissent.

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