Kevin Malone v. Stanley Black & Decker, Inc., 965 F.3d 499

Kevin Malone injured his hand when a Craftsman table saw guard came off; the Malones sued Sears/Craftsman entities and Rexon Industrial Corp. Ltd. (Taiwanese manufacturer) in Ohio state court after a later recall.
Rexon removed the case to federal court on diversity grounds and moved to dismiss under Fed. R. Civ. P. 12(b)(2) for lack of personal jurisdiction; for the motion Rexon conceded it manufactured the saw and, arguendo, that it purposefully availed itself of Ohio.
The complaint alleged the saw was purchased in Ohio, alleged generic negligent design/manufacture/warning defects by “Defendants,” and asserted Rexon conducted business and caused tortious injury in Ohio, but lacked detailed facts about Rexon’s Ohio contacts or revenue.
The district court treated the record on written submissions, credited an affidavit from Rexon denying targeted Ohio contacts, denied jurisdictional discovery, and dismissed for lack of specific personal jurisdiction under Ohio’s long‑arm statute (focusing on Ohio Rev. Code § 2307.382(A)(4)).
The Sixth Circuit vacated and remanded, holding the complaint made a prima facie showing of jurisdiction and the district court erred by crediting Rexon’s affidavit and denying jurisdictional discovery when resolving the motion on the papers.

Issue	Plaintiff's Argument	Defendant's Argument	Held
General jurisdiction	Malones did not press general jurisdiction; alleged enough contacts to dispute dismissal	Rexon lacked continuous/systematic contacts making it "at home" in Ohio	No general jurisdiction; plaintiff failed to make prima facie showing for general jurisdiction
Specific jurisdiction under Ohio Rev. Code § 2307.382(A)(4) (location of injury; defendant's contacts)	Malone: injury occurred in Ohio; Rexon purposefully availed and derived substantial revenue from saws used in Ohio	Rexon: manufacture, sale and shipment to Sears in California were not directed at Ohio, so no proximate connection	Court inferred injury occurred in Ohio and found the complaint, viewed favorably, made a prima facie showing of contacts sufficient to proceed; district court’s contrary dismissal was error
Burden, use of defendant affidavit, and jurisdictional discovery	Malones: only prima facie showing required on written submissions and discovery should be allowed to develop contacts evidence	Rexon: affidavit disproved jurisdiction; discovery unnecessary and would be fishing	When motion is resolved on papers, plaintiff’s prima facie showing stands and defendant cannot defeat it by unauthenticated affidavit; denying discovery and crediting affidavit was error; remand for further proceedings (discovery/evidentiary hearing left to district court)

Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915 (2011) (distinguishes general and specific jurisdiction)
Int'l Shoe Co. v. Washington, 326 U.S. 310 (1945) (minimum contacts framework for due process)
J. McIntyre Mach., Ltd. v. Nicastro, 564 U.S. 873 (2011) (purposeful availment depends on defendant's conduct and market realities)
Asahi Metal Indus. Co. v. Superior Ct., 480 U.S. 102 (1987) (considerations for purposeful availment and reasonableness)
Bridgeport Music, Inc. v. Still N The Water Pub., 327 F.3d 472 (6th Cir. 2003) (limits on jurisdiction when sales are not purposefully directed to the forum)
Int'l Techs. Consultants, Inc. v. Euroglas S.A., 107 F.3d 386 (6th Cir. 1997) (state long‑arm statute and due process constraints)
Schneider v. Hardesty, 669 F.3d 693 (6th Cir. 2012) (standards for resolving 12(b)(2) motions on written submissions vs. discovery/hearing)
Theunissen v. Matthews, 935 F.2d 1454 (6th Cir. 1991) (burden‑shifting framework for jurisdictional challenges)
Serras v. First Tenn. Bank Nat. Ass'n, 875 F.2d 1212 (6th Cir. 1989) (procedural choices for resolving jurisdictional motions)
Pebble Beach Co. v. Caddy, 453 F.3d 1151 (9th Cir. 2006) (when jurisdictional discovery may be denied due to attenuated allegations)