Ethridge v. Samsung SDI
137 F.4th 309
5th Cir.2025Background
- James Ethridge, a Texas resident, was injured when a Samsung 18650 lithium-ion battery purchased online exploded in his pocket in Texas.
- The battery was bought from a third-party Wyoming seller on Amazon, not directly from Samsung.
- Samsung SDI, a South Korean corporation with no physical presence in the US, sells 18650 batteries to Texas companies (HP, Dell, Black & Decker), but not directly to Texas consumers.
- Ethridge sued Samsung and others for personal injury; only the issue of personal jurisdiction over Samsung remained after other claims were resolved.
- The district court dismissed Ethridge's claims against Samsung for lack of personal jurisdiction, finding the connections to Texas insufficient under the Fourteenth Amendment.
- Ethridge appealed, arguing that Texas courts should have specific personal jurisdiction over Samsung for his injury.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Specific Personal Jurisdiction | Samsung purposefully availed itself of Texas by selling 18650 batteries to entities in Texas, and Ethridge was injured in Texas. | Samsung only sold to businesses, not consumers; injury resulted from third-party sales outside its control. | Jurisdiction proper: purposeful availment found through business contacts and relatedness satisfied by in-state injury. |
| Relatedness of Claims to Contacts | Ethridge's claim relates to Samsung's Texas activities because same model batteries were sold into Texas and exploded in Texas. | No causal link between business-to-business sales and Ethridge's consumer injury; unrelated distribution channels. | Ford's "same product plus in-state injury" standard met; direct sale to consumer not required. |
| Different Market Argument | The relevant market is Texas as a whole, not limited by distribution channels. | Only sales to business/industrial, not consumers, so claims aren't related to Texas contacts. | Court rejects "different market" approach as unworkable and unsupported by recent Supreme Court precedent. |
| Fair Play & Substantial Justice | Texas has an interest in protecting its residents; Samsung can litigate in Texas. | Unfair to hale Samsung into Texas courts for injuries from channels it did not control or target. | Texas’s exercise of jurisdiction is fair and reasonable in this context. |
Key Cases Cited
- International Shoe Co. v. Washington, 326 U.S. 310 (establishes minimum contacts standard for personal jurisdiction)
- Ford Motor Co. v. Mont. Eighth Jud. Dist. Ct., 592 U.S. 351 (clarifies "arise out of or relate to" standard for specific personal jurisdiction)
- Bristol-Myers Squibb Co. v. Superior Ct., 582 U.S. 255 (limits specific jurisdiction when plaintiff’s claims lack connection to the forum)
- World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (discusses foreseeability and fairness in the jurisdiction over out-of-state defendants)
- Daimler AG v. Bauman, 571 U.S. 117 (limits general jurisdiction to a corporation’s place of incorporation or principal place of business)
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (discusses purposeful availment and fairness factors in personal jurisdiction)