Yamashita v. LG Chem, Ltd, 518 P.3d 1169

Matt Yamashita, a Hawaiʻi resident, sued out-of-state corporations (LG Chem, Ltd. and LG Chem America, Inc.) over an exploding electronic cigarette in Hawaiʻi state court.
The case was removed to the U.S. District Court for the District of Hawaiʻi, which dismissed for lack of personal jurisdiction, concluding the defendants’ in-state activities were not the but‑for cause and the claims did not “arise from” those acts.
The Ninth Circuit, applying Hawaiʻi law and federal due process, found Hawaiʻi precedent unclear after the U.S. Supreme Court’s decision in Ford Motor Co. v. Montana Eighth Judicial District Court and certified two questions to the Hawaiʻi Supreme Court.
The certified questions asked whether Hawaiʻi courts may assert jurisdiction when an injury “relates to” but does not “arise from” in‑state acts, and whether HRS § 634‑35 permits jurisdiction to the full extent allowed by the Fourteenth Amendment after Ford.
The Hawaiʻi Supreme Court explained HRS § 634‑35 was adopted to align the State’s long‑arm with the constitutional limits identified in Cowan, and held that the statute permits jurisdiction to the full extent of federal due process, including Ford’s “relates to” standard.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Hawaiʻi courts may assert personal jurisdiction when the plaintiff’s injury “relates to,” but does not “arise from,” defendant’s in‑state acts (post‑Ford).	Yamashita: Ford allows jurisdiction when claim relates to in‑state conduct even absent strict but‑for causation.	Defendants: HRS § 634‑35 requires claims to “arise from” in‑state acts (i.e., stricter causation), so jurisdiction is improper.	Yes. HRS § 634‑35 incorporates the federal due process standard; jurisdiction is permissible where the claim “relates to” the defendant’s forum contacts if due process is satisfied.
Whether HRS § 634‑35 permits Hawaiʻi courts to exercise jurisdiction to the full extent permitted by the Fourteenth Amendment after Ford.	Yamashita: The statute was intended to reach the limits of federal due process and thus allows jurisdiction to the full constitutional extent.	Defendants: The statute’s language limits jurisdiction beyond federal due process and should be read narrowly.	Yes. The court held the long‑arm statute authorizes jurisdiction to the full extent allowed by federal due process (so long as due process is met).

Ford Motor Co. v. Montana Eighth Judicial Dist. Ct., 141 S. Ct. 1017 (2021) (holds forum contacts that “relate to” a plaintiff’s claim can support specific jurisdiction even without strict but‑for causation)
Cowan v. First Ins. Co. of Hawaii, Ltd., 608 P.2d 394 (Haw. 1980) (explains HRS § 634‑35 was adopted to expand Hawaiʻi jurisdiction to the limits of due process)
Norris v. Six Flags Theme Parks, Inc., 74 P.3d 26 (Haw. 2003) (articulates Hawaiʻi’s two‑step personal jurisdiction inquiry: long‑arm statute then due process)
Kailieha v. Hayes, 536 P.2d 568 (Haw. 1975) (applied long‑arm but found federal due process lacking; illustrates due process can be dispositive)
Shaw v. North Am. Title Co., 876 P.2d 1291 (Haw. 1994) (followed Cowan in treating the long‑arm statute as aligned with due process)