159 So. 3d 629
Ala.2014Background
- Tiffin Motorhomes sued Edgetech (now Quanex I.G. Systems) and others in Franklin County, Alabama, alleging defective Super Spacer (EPDM) used in insulated-glass windows caused failures and warranty costs.
- Edgetech manufactured and sold Super Spacer in bulk to Thompson (a Michigan insulated-glass manufacturer); Thompson supplied completed insulated-glass units to Wynne (Alabama), which sold windows to Tiffin.
- Edgetech moved to dismiss for lack of personal jurisdiction (Rule 12(b)(2)); the trial court denied the motion and Edgetech petitioned for mandamus to compel dismissal.
- Edgetech submitted an affidavit showing limited contacts with Alabama: no offices or employees there, only two small customers (not for the product at issue), no direct sales to Wynne or Tiffin, and no targeting of Alabama; its sale was to Thompson in Michigan and involvement ended upon delivery.
- Tiffin alleged Edgetech did business in Alabama, marketed through distributors/sales agents, and placed products into the stream of commerce, but it presented no evidence that Edgetech expected or targeted sales into Alabama.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| General jurisdiction — whether Edgetech's Alabama contacts are "continuous and systematic" to be "at home" in Alabama | Edgetech has systematic/continuous contacts via production facility in Decatur (Quanex), marketing through distributors, and knowledge its products reach Alabama | Edgetech is Ohio-based, no Alabama offices/employees, de minimis sales in Alabama, no physical presence, and sales at issue were to Michigan Thompson | Not established — contacts were too limited and sporadic to support general jurisdiction; trial court erred in denying dismissal |
| Specific jurisdiction — whether Edgetech purposefully availed itself or targeted Alabama (stream-of-commerce) | Edgetech placed Super Spacer into stream of commerce and knew products would reach Alabama; thus Alabama courts have specific jurisdiction | Edgetech sold only to Thompson in Michigan, had no relationship with Thompson’s customers or Wynne/Tiffin, and lacked evidence of targeting or expectation that the product would be sold in Alabama | Not established — plaintiff failed to show Edgetech purposefully availed itself of Alabama or expected sales there; specific jurisdiction lacking |
Key Cases Cited
- International Shoe Co. v. Washington, 326 U.S. 310 (established "minimum contacts" due process test)
- World–Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (foreseeability alone insufficient for jurisdiction; purposeful availment required)
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (purposeful availment and reasonableness factors for jurisdiction)
- Goodyear Dunlop Tires Operations, S.A. v. Brown, 131 S. Ct. 2846 (general jurisdiction requires defendant to be "at home" in forum)
- Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408 (limits on general jurisdiction)
- Perkins v. Benguet Consol. Mining Co., 342 U.S. 437 (textbook general-jurisdiction example)
- Asahi Metal Indus. Co. v. Superior Court, 480 U.S. 102 (stream-of-commerce jurisprudence and fractured opinions)
- J. McIntyre Machinery, Ltd. v. Nicastro, 131 S. Ct. 2780 (plurality on stream-of-commerce and targeting; did not resolve split)
- Ex parte DBI, Inc., 23 So. 3d 635 (Ala. 2009) (Alabama adoption of stream-of-commerce analysis to find specific jurisdiction)
- Ex parte Lagrone, 839 So. 2d 620 (Ala. 2002) (prior Alabama case relying on stream-of-commerce facts)