Robinson v. Harley-Davidson Motor Co.
270 P.3d 367
Or. Ct. App.2012Background
- Robinson, an Oregon resident, rode a Harley-Davidson motorcycle in Idaho; suspected front-wheel instability led to service in Idaho Falls.
- Plaintiff sustained injuries in Wyoming the day after service work by the Idaho dealership.
- Robinson brought suit in Multnomah County against Grand Teton Cycles, LLC and Harley-Davidson entities for negligence, strict liability, and warranty claims.
- Defendant moved to dismiss for lack of personal jurisdiction under ORCP 21 A(2); trial court granted the motion.
- Court of Appeals reviews only whether Oregon’s ORCP 4 L long-arm reaches defendant given minimum contacts and relatedness; the court ultimately affirms the dismissal.
- The court determines the alleged Oregon contacts were not related to the substance of Robinson’s claims, so jurisdiction could not be asserted.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ORCP 4 L supports jurisdiction over defendant. | Robinson argues defendant purposefully directed activities at Oregon; claims arise from those contacts. | Defendant contends no relatedness between Oregon activities and the claims; long-arm cannot reach. | No jurisdiction; claims do not arise from Oregon contacts. |
| Whether the substantive relevance test constrains arising-out-of/relating-to analysis. | Michelin/Horn show relatedness via Oregon contacts. | No substantive relevance; Oregon activities not tied to the negligence or warranty claims. | Substantive relevance yields no relation to the claims. |
| Whether a but-for test should govern relatedness under ORCP 4 L. | But-for test should apply per Shute/Circus Circus dissent. | But-for test rejected by Circus Circus and controlling Oregon law. | But-for test rejected; not adopted. |
Key Cases Cited
- State ex rel. Circus Circus Reno, Inc. v. Pope, 317 Or. 151 (1993) (establishes two-part minimum contacts test under ORCP 4 L; relatedness and reasonableness)
- Michelin v. Wells, 294 Or. 296 (1982) (substantive relevance test for relatedness; contacts must relate to substance of claim)
- Horn v. Seacatcher Fisheries, Inc., 128 Or.App. 585 (1994) (adopts relatedness test; recruitment/hosting activities not enough for Oregon-related negligence in Alaska waters)
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985) (minimum contacts and reasonableness framework for due process)
- Nike USA, Inc. v. Pro Sports Wear, Inc., 208 Or.App. 531 (2006) (plaintiff bears burden to plead facts showing jurisdiction)