Noll v. Amer. Biltrite Inc., 91998-4

Plaintiff Donald Noll (now represented by his estate) developed malignant mesothelioma after cutting Certain‑Teed asbestos‑cement pipe in Washington (1977–1979); Certain‑Teed manufactured the pipe at a Santa Clara, CA plant.
Special Electric (and related "Special" companies) supplied crocidolite and chrysotile asbestos to Certain‑Teed; Special provided roughly 95% of Certain‑Teed’s crocidolite and had a multi‑year supply contract.
Complaint alleged defendants placed asbestos into the stream of commerce and that Washington courts had jurisdiction because defendants transacted business in King County; no specific factual allegations tied Special’s own conduct to Washington.
Special moved to dismiss for lack of specific personal jurisdiction; the trial court granted dismissal without prejudice. Division One of the Court of Appeals reversed, finding a stream‑of‑commerce theory supported jurisdiction.
Washington Supreme Court granted review, considered its recent decision in State v. LG Electronics and other stream‑of‑commerce authority, and remanded—holding that on the allegations before it, Noll failed to plead that Special purposefully availed itself of Washington law, so dismissal was proper.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Washington has specific personal jurisdiction over Special under a stream‑of‑commerce theory	Noll: Special supplied large quantities of asbestos to Certain‑Teed; Certain‑Teed manufactured pipes sold into Washington, so Special’s component sales foreseeably resulted in products entering Washington	Special: Its contacts were with Certain‑Teed in California only; it had no offices, agents, property, or purposeful conduct directed to Washington—mere sale to an out‑of‑state manufacturer is insufficient	Held: Dismissal affirmed for lack of specific jurisdiction on the record presented; mere supply of a component to an out‑of‑state manufacturer that separately sold finished goods in Washington did not show Special purposefully availed itself of Washington law

State v. LG Electronics, Inc., 186 Wn.2d 169 (Wash. 2016) (clarifies stream‑of‑commerce analysis under Justice Breyer’s McIntyre concurrence and what facts suffice to show purposeful availment)
J. McIntyre Machinery Ltd. v. Nicastro, 564 U.S. 873 (2011) (plurality and Breyer concurrence on limits of stream‑of‑commerce; sale through nationwide distributor not enough without something more)
Walden v. Fiore, 571 U.S. 277 (2014) (jurisdictional inquiry must focus on defendant’s own contacts with the forum, not third parties’ connections)
International Shoe Co. v. Washington, 326 U.S. 310 (1945) (minimum contacts/ purposeful availment framework)
Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985) (purposeful availment and fair play/substantial justice test)
Goodyear Dunlop Tire Operations, S.A. v. Brown, 564 U.S. 915 (2011) (distinguishes specific vs. general jurisdiction)
Asahi Metal Ind. Co. v. Superior Court, 480 U.S. 102 (1987) (stream‑of‑commerce discussion and relatedness factors)