Nicastro v. McIntyre (Alabama)
1. Nicastro injured his hand on a machine from McIntyre (incorporated business in UK) and filed suit against McIntyre in New Jersey; McIntyre argued no personal jurisdiction and the state court said that the company should’ve known that the New Jersey would get the product
a. There was only one machine by McIntyre in New Jersey and it was the one that caused the accident
2. SCOTUS reversed
a. One machine isn’t enough for general jurisdiction
b. Specific jurisdiction?
i. McIntyre never engaged in activities in New Jersey that revealed an intent to invoke/benefit from the protection of New Jersey state laws à didn’t purposefully avail themselves to the laws of NJ
c. Stream of commerce is problematic for McIntyre because they manufacture products that they willingly put into the stream of commerce and those products can go anywhere à can look to the stream of commerce after determining if purposeful availment was met
3. This case muddied the waters of the stream of commerce argument because if 1 machine isn’t enough for specific jurisdiction, then what about 2, 3, or 4 machines?
a. How many is enough? Still up in the air.