George Williams v. Yamaha Motor Corp. USA
2017 U.S. App. LEXIS 5210
| 9th Cir. | 2017Background
- Twenty named plaintiffs (class) bought Yamaha first-generation four-stroke outboard motors (2000–2004) that allegedly suffered premature dry-exhaust corrosion causing failure at ~500–700 hours instead of expected ~2000 hours.
- Motors were designed and manufactured by Yamaha Motor Co., Ltd. (YMC) in Japan and imported/marketed in California by its wholly‑owned subsidiary Yamaha Motor Corp., U.S.A. (YMUS).
- Plaintiffs asserted warranty, consumer‑protection, and related state statutory claims, consolidated related cases, and filed a second amended complaint alleging presale knowledge and safety hazard from the defect.
- YMC moved to dismiss for lack of personal jurisdiction; YMUS moved to dismiss for failure to state a claim under Rule 12(b)(6).
- District court dismissed YMC for lack of personal jurisdiction and dismissed plaintiffs’ consumer fraud claims against YMUS with prejudice; plaintiffs appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether federal court has general jurisdiction over YMC | YMC’s U.S. contacts (via YMUS), sales, and litigation history make it "at home" in California or permit imputing YMUS contacts | YMC is incorporated and headquartered in Japan; contacts do not render it essentially at home in CA and plaintiffs didn’t show alter‑ego | No general jurisdiction: YMC not "at home" in CA; plaintiffs failed to show alter‑ego/impute contacts |
| Whether federal court has specific jurisdiction over YMC | YMUS’s in‑state activities can be imputed to YMC under an agency theory to create a suit‑related connection | YMC had no purposeful contacts with CA; plaintiffs failed to show control/agency so contacts can’t be imputed | No specific jurisdiction: plaintiffs failed to plead agency/control sufficient to impute YMUS’s contacts to YMC |
| Whether plaintiffs adequately pleaded presale knowledge of defect | Internal customer complaints (40–50, dedicated CRM center) beginning as early as 2001 show YMUS knew of corrosion pre‑sale | Customer complaints are anecdotal and insufficient; timing inconsistent with alleged hours‑to‑failure | Adequately pleaded presale knowledge: CRM system, volume, and corporate reporting made inference plausible |
| Whether the alleged defect constituted an unreasonable safety hazard (required for consumer‑fraud claims) | Premature corrosion can cause fires or loss of steering power posing safety risks | Corrosion is accelerated normal wear (post‑warranty timing); risk is speculative and consumers are warned about steering loss | Failure to plead unreasonable safety hazard: allegations show accelerated wear, speculative safety risks; consumer‑fraud claims dismissed |
Key Cases Cited
- Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915 (2011) (general jurisdiction requires defendant be essentially at home in forum)
- Int’l Shoe Co. v. Washington, 326 U.S. 310 (1945) (minimum contacts due process standard)
- Daimler AG v. Bauman, 571 U.S. 117 (2014) (limits general jurisdiction; parent‑subsidiary contacts not enough absent being at home)
- Walden v. Fiore, 571 U.S. 277 (2014) (specific jurisdiction requires defendant’s own forum contacts creating substantial connection)
- Ranza v. Nike, Inc., 793 F.3d 1059 (9th Cir. 2015) (alter‑ego test for imputing jurisdiction; stringent standards)
- Doe v. Unocal Corp., 248 F.3d 915 (9th Cir. 2001) (agency theory test for imputing contacts)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility pleading standard)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (conclusory allegations not credited on motion to dismiss)