Sproul v. Rob & Charlies, Inc.
2013 NMCA 072
N.M.2012Background
- R&C filed an indemnity claim against Joy Co. in a personal-injury case involving a defective GT bicycle component.
- Joy Co. manufactured the quick-release mechanism; its principal places of business are in Taiwan and China, with Chinese manufacturing facilities.
- Joy Co. sold products worldwide via a network including J&B Importers, serving the New Mexico market from Colorado.
- Sproul’s 1988 GT bicycle incorporated Joy Co.’s quick-release mechanism; Sproul was injured in New Mexico in 2003.
- The district court dismissed for lack of personal jurisdiction, finding no minimum contacts or reasonableness, and certified interlocutory appeal.
- The NM Court of Appeals reverses, holding Joy Co. subject to specific jurisdiction under the stream-of-commerce theory and NM long-arm statute.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Joy Co. is subject to New Mexico’s long-arm statute | R&C contends Joy Co. has sufficient actor-directed contacts in NM. | Joy Co. lacks continuous, systematic, or purposeful NM contacts. | Yes; long-arm and due process satisfied for specific jurisdiction. |
| Whether Joy Co. is subject to general jurisdiction in New Mexico | Joy Co. maintains continuous and systematic NM contacts via distribution. | Joy Co. has no NM incorporation, operations, or manufacturing here. | No general jurisdiction found. |
| Whether the stream-of-commerce theory supports specific jurisdiction | Joy Co. placed its quick-release mechanism into the stream of commerce with intent to distribute, including NM. | Asahi/J.McIntyre require targeted forum-directed activity; mere stream-of-commerce is insufficient. | Sufficient minimum contacts under World-Wide Volkswagen and stream-of-commerce to subject Joy Co. to NM specific jurisdiction. |
| Whether exercising jurisdiction would offend traditional notions of fair play and substantial justice | NM has strong interest; Joy Co. has several US activities; burden is slight on Joy Co. | Defending in NM would be burdensome for a foreign manufacturer. | Factors favor jurisdiction; not unduly burdensome given Joy Co.’s US-market activities. |
Key Cases Cited
- World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (1980) (foreseeability alone insufficient; must target forum market)
- Goodyear Dunlop Tires Operations, S.A. v. Brown, 131 S. Ct. 2846 (2011) (limits general jurisdiction to essentially at-home defendants; stream of commerce context noted)
- Asahi Metal Industry Co. v. Superior Court, 480 U.S. 102 (1987) (fractured plurality on stream-of-commerce; approaches differ on purposeful availment)
- J. McIntyre Machinery, Ltd. v. Nicastro, 131 S. Ct. 2780 (2011) (plurality declines universal stream-of-commerce rule; tests vary by justice)
- Visarraga v. Gates Rubber Co., 104 N.M. 143, 717 P.2d 596 (Ct. App. 1986) (limits on stream-of-commerce reach; attenuated contacts insufficient for jurisdiction)
- Roberts v. Piper Aircraft Corp., 100 N.M. 363, 670 P.2d 974 (Ct. App. 1983) (advertising, solicitation, and awareness of NM market support purposeful availment)
- Blount v. TD Publishing Corp., 77 N.M. 384, 423 P.2d 421 (1966) (nationwide distribution of defective products can support jurisdiction)