J. McIntyre Machinery, Ltd. v. Nicastro
131 S. Ct. 2780
| SCOTUS | 2011Background
- Nicastro injured his hand in New Jersey using a metal-shearing machine manufactured by J. McIntyre; the machine was made in England.
- Nicastro filed a products-liability suit in New Jersey state court seeking to hold McIntyre liable where the injury occurred.
- New Jersey relied on a stream-of-commerce theory, deeming jurisdiction proper because McIntyre knew its products could be sold nationwide and distributed through a U.S. distributor.
- McIntyre had no New Jersey office, no advertising there, no NJ-specific shipments, and few machines ended up in New Jersey;
- The New Jersey Supreme Court upheld jurisdiction on stream-of-commerce grounds, prompting a constitutional challenge under the Due Process Clause.
- The Supreme Court reversed, holding that due process requires purposeful availment and that the record did not show McIntyre purposefully availing itself of New Jersey.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether New Jersey may exercise jurisdiction over a foreign manufacturer without presence or consent. | Nicastro argues the defendant purposefully availed itself by targeting the U.S. market | McIntyre argues no purposeful availment toward New Jersey; isolated NJ presence is insufficient | No jurisdiction; reversed |
| Whether the stream-of-commerce theory can justify specific jurisdiction over an absent defendant. | Nicastro relies on stream-of-commerce implications to show foreseeability and purpose | McIntyre contends stream-of-commerce cannot substitute for purposeful availment | Rejected as controlling authority |
| Whether the defendant’s conduct shows purposeful availment sufficient for NJ specific jurisdiction. | Nicastro points to national distribution efforts and trade-show presence as targeting the U.S. | McIntyre asserts no NJ-directed activity or targeting; record lacks NJ contacts | Not established |
| Whether Congress or other doctrines could alter the jurisdictional analysis or venue in this context. | Nicastro does not rely on Congressional authorization; asks NJ to exercise jurisdiction | McIntyre notes no need to address Congressional power in this case | Not addressed as controlling authority; jurisdiction not proper |
Key Cases Cited
- International Shoe Co. v. Washington, 326 U.S. 310 (1945) (establishes minimum contacts and fair play/fairness test)
- World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (1980) (foreseeability alone not enough for jurisdiction; presence not implied)
- Asahi Metal Industry Co. v. Superior Court of Cal., Solano County, 480 U.S. 102 (1987) (discusses stream-of-commerce and the need for something more than mere placement)
- Hanson v. Denckla, 357 U.S. 235 (1958) (purposeful availment as basis for jurisdiction)
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985) (purposeful availment governs specific jurisdiction over out-of-state defendants)
- Shaffer v. Heitner, 433 U.S. 186 (1977) (reaffirms that jurisdiction is determined by the relationship among defendant, forum, and litigation)
- Goodyear Dunlop Tires Operations, S. A. v. Brown, 131 S. Ct. 2846 (2011) (reiterates limits of general jurisdiction and framework for specific jurisdiction)
- Insurance Corp. of Ireland v. Compagnie des Bauxites de Guinee, 456 U.S. 694 (1982) (addresses due process limits on state power and submission concepts)
- Helicopteros Nacionales de Colombia, S. A. v. Hall, 466 U.S. 408 (1984) (illustrates limits of general jurisdiction based on regular business contacts)