J. McIntyre Machinery, Ltd. v. Nicastro case brief summary
131 S.Ct. 2780 (2011)
DISCUSSION
CONCLUSION
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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131 S.Ct. 2780 (2011)
CASE SYNOPSIS
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.DISCUSSION
- 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.
CONCLUSION
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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