Yanmar Co. v. Slater
2012 Ark. 36
| Ark. | 2012Background
- Wanda Slater sued Yanmar Japan, Yanmar America, and others after Rudolph Slater died in a tractor rollover of a 1977 YM2000 tractor that had gray-market history.
- Tractor originated in Japan, later circulated via LuckCompany/Lucky Company, LCI Equipments, and Chris Elder Enterprises before reaching Slater.
- Jury awarded $2.5 million; apportionment: Yanmar Japan 39%, Yanmar America 25%, LCI 29%, Slater 7%.
- Yanmar Japan challenged personal jurisdiction; Yanmar America challenged duty and causation, plus evidentiary rulings.
- Arkansas circuit court denied defenses; appeals proceeded, issues certified for the Arkansas Supreme Court guidance on jurisdiction and duty.
- This court reversed as to Yanmar Japan for lack of personal jurisdiction and reversed/dismissed as to Yanmar America for lack of duty and substantial evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Arkansas has personal jurisdiction over Yanmar Japan | Slater argues Yanmar Japan had continuous contacts via its subsidiary and parts distribution sufficient for general jurisdiction. | Yanmar Japan contends no continuous, systematic contacts; Goodyear and related authority foreclose general jurisdiction based on distant distribution. | No general jurisdiction; circuit court erred in exercising jurisdiction over Yanmar Japan. |
| Whether Yanmar America owed a duty and was negligent | Slater contends Yanmar America had a duty due to its role in the brand and gray-market activity, and breached it causing injury. | Yanmar America owed no duty to Slater; it was not involved in design/manufacture, sale, or gray-market distribution of the tractor, and duties cannot be imputed. | Yanmar America owed no duty; directed verdict for Yanmar America was reversible error; court reversed and dismissed as to Yanmar America. |
| Whether the circuit court properly allowed or excluded evidence relating to ROPS and post-sale warning duties | Slater contends evidence supported post-sale duty to warn or retrofit the tractor. | Defendants argue no duty to warn/retrofit; evidence improper to support negligence against them. | Not separately addressed as dispositive after disposition on jurisdiction and duty; overall reversal as to Japan and America. |
Key Cases Cited
- International Shoe Co. v. Washington, 326 U.S. 310 (Supreme Court) (establishes minimum-contacts due process test for jurisdiction)
- World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (Supreme Court) (purposeful availment and foreseeability required for jurisdiction)
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (Supreme Court) (purposeful availment; fair-play and substantial justice)
- Goodyear Dunlop Tires Operations v. Brown, 131 S. Ct. 2846 (Supreme Court) (limits general jurisdiction; must be continuous and systematic)
- Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408 (Supreme Court) (distinction between general and specific jurisdiction)
- Anderson v. Dassault Aviation, 361 F.3d 449 (8th Cir. 2004) (attribution of subsidiary contacts to parent under certain circumstances)
- Viasystems, Inc. v. EBM-Papst St. Georgen GmbH & Co., KG, 646 F.3d 589 (8th Cir. 2011) (attribution requires more than mere product flow; parental control/dominance necessary)
- Epps v. Stewart Information Services Corp., 327 F.3d 642 (8th Cir. 2003) (alter ego theory in jurisdictional analysis requires domination of subsidiary)
- Gibbs v. PrimeLending, 381 S.W.3d 829 (Ark. 2011) (Arkansas due-process analysis in personal jurisdiction)
- Hall v. Rental Mgmt., Inc., 323 Ark. 143 (Ark. 1996) (voluntary assumption of duty; need for ordinary care when acting)