Ford Motor Co. v. Montana Eighth Judicial Dist.
141 S. Ct. 1017
| SCOTUS | 2021Background
- Two products‑liability suits against Ford: (1) Gullett (Mont.) — a 1996 Ford Explorer tread separation caused a fatal rollover; (2) Bandemer (Minn.) — a 1994 Crown Victoria airbag failure caused serious brain injury.
- Each plaintiff is a resident of the forum State and was injured in that State.
- The specific vehicles were designed and manufactured outside the forum States and were first sold out of state; they later entered the forums via resale/relocation.
- Ford conducts substantial, continuous business in Montana and Minnesota: advertising, many dealerships, sales (including same models), parts distribution, and repair/service networks.
- Ford moved to dismiss for lack of personal jurisdiction; Montana and Minnesota supreme courts upheld jurisdiction; the U.S. Supreme Court affirmed specific jurisdiction over Ford.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the forums have specific personal jurisdiction over Ford | The plaintiffs (Gullett, Bandemer) argued Ford purposefully served the forum markets for the same models, and the in‑state use/injury ties the claims to Ford’s forum activities | Ford argued due process requires the defendant’s forum conduct to have caused the plaintiff’s claim — i.e., the car must have been designed, manufactured, or first sold in the forum (a causation‑only rule) | The Court held specific jurisdiction exists: a causal link is not the only permissible connection; serving a forum market for the product that malfunctions there suffices |
| Whether general jurisdiction exists in the forums | Plaintiffs did not rely on general jurisdiction | Ford conceded it is not “at home” in Montana or Minnesota (incorporated in Delaware; principal place in Michigan) | General jurisdiction not present; decision rests on specific jurisdiction |
| Whether Bristol‑Myers or Walden forecloses jurisdiction here | Plaintiffs: those cases are distinguishable because plaintiffs here are forum residents injured in‑state by in‑state use of the product | Ford: cites Bristol‑Myers and Walden to argue forum residence/place of injury cannot support jurisdiction absent defendant’s causal forum conduct | The Court distinguished both: Bristol‑Myers lacked forum residents or in‑state injury; Walden involved no defendant forum contacts — here Ford has extensive forum contacts |
| Proper test for specific jurisdiction (causation vs. broader affiliation) | Plaintiffs urged the established International Shoe/Burger King framework and World‑Wide Volkswagen principle that serving a forum market for a product that malfunctions in the forum supports jurisdiction | Ford urged a strict but‑for/cause‑of‑the‑claim requirement tying jurisdiction only to places of design, manufacture, or first sale | The Court reaffirmed International Shoe framework: claims must “arise out of or relate to” forum contacts; “relate to” can encompass a non‑causal affiliation such as deliberately serving the forum market for the product that caused in‑state injury |
Key Cases Cited
- International Shoe Co. v. Washington, 326 U.S. 310 (foundational minimum‑contacts due‑process test)
- World‑Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (serving a forum market for a product that malfunctions there can support specific jurisdiction)
- Bristol‑Myers Squibb Co. v. Superior Court of Cal., San Francisco Cty., 582 U.S. _ (distinguished; requires connection between forum and specific claims)
- Walden v. Fiore, 571 U.S. 277 (distinguished; where defendant has no forum contacts, plaintiff residence/place of injury alone is insufficient)
- Daimler AG v. Bauman, 571 U.S. 117 (general‑jurisdiction “at home” rule)
- Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915 (general vs. specific jurisdiction framework)
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (purposeful availment and fair‑warning rationale)
- Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408 (relationship among defendant, forum, and litigation as foundation for specific jurisdiction)