Soria v. Chrysler Canada, Inc.
958 N.E.2d 285
Ill. App. Ct.2011Background
- Collision in Rockford, IL; plaintiff Ester Soria injured when airbag door fractured on a vehicle assembled by Chrysler Canada in Windsor and sold to Illinois consumer.
- Plaintiff alleged Chrysler Canada contributed to design/assembly of the airbag system and knew vehicles would be distributed in the US, including Illinois.
- Chrysler Canada moved to dismiss for lack of personal jurisdiction; trial court denied the motion; this appeal followed.
- Chrysler United States (Chrysler LLC) was originally named but later dismissed; Chrysler Canada argued it was merely a final assembler with no Illinois contacts.
- Evidence showed Chrysler Canada estimated 82% of its US-bound production, including Illinois, and that it indirectly shipped vehicles into Illinois through Chrysler United States.
- Court held Chrysler Canada had sufficient minimum contacts with Illinois to support specific jurisdiction under the Illinois long-arm statute and due process requirements.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Chrysler Canada has minimum contacts with Illinois | Soria: Chrysler Canada knowingly serves the US market and targets Illinois via stream of commerce | Chrysler Canada: no direct Illinois contacts or directed acts; acts by Chrysler United States not imputable | Yes; Chrysler Canada has minimum contacts due to stream-of-commerce and targeted US market. |
| Whether the action arose out of Chrysler Canada's Illinois contacts | Soria: injuries arose from a vehicle assembled for Chrysler United States distributed in Illinois | Chrysler Canada: contacts are incidental; not the sole cause of injury | Yes; injuries related to a vehicle assembled in Canada distributed to Illinois. |
| whether Illinois can exercise jurisdiction reasonably | Soria: Illinois interest in redress and safety, relative burden on plaintiff | Chrysler Canada: forum burden on foreign defendant | Yes; Illinois interest and plaintiff's relief outweigh defendant burden. |
Key Cases Cited
- World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (U.S. 1980) (stream-of-commerce foreseeability supporting jurisdiction in certain circumstances)
- Asahi Metal Industry Co. v. Superior Court, 480 U.S. 102 (U.S. 1987) (stream-of-commerce scope split; fairness considerations in minimum contacts)
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (U.S. 1985) (purposeful availment and fair play; minimum contacts test for specific jurisdiction)
- J. McIntyre Machinery, Ltd. v. Nicastro, 131 S. Ct. 2780 (U.S. 2011) (jurisdiction depends on defendant's targeting forum; narrow vs broad stream-of-commerce theories)
- Gray v. American Radiator & Standard Sanitary Corp., 176 N.E.2d 761 (Ill. 1961) (manufacturing liability for components shipped into Illinois; effects in state)