Young v. Ford Motor Company
90 N.E.3d 647
| Ill. App. Ct. | 2017Background
- In 2009 plaintiffs bought a 2000 Lincoln Navigator; in 2010 Dakar custom wheels (manufactured in China) were installed on the vehicle; a wheel separated in Illinois in 2010, causing injuries and a death.
- Plaintiffs sued multiple defendants, including Chinese manufacturers Jinfei Holding Group Co., Ltd. and Zhejiang Jinfei Kaida Wheel Co., Ltd. (the Jinfei defendants), alleging defective wheels and asserting Illinois jurisdiction.
- Jinfei moved to dismiss for lack of personal jurisdiction under Illinois law and federal due process; trial court granted the motion in Sept. 2016 and denied reconsideration in Jan. 2017.
- Evidence showed Jinfei companies were incorporated and located in China, not registered in Illinois, had no Illinois offices, assets, employees, or direct sales in Illinois, and completed transactions F.O.B. a Chinese port; UPC and U.S. distributors arranged U.S. shipment destinations (including Chicago).
- The trial court found only awareness that products could arrive in Chicago (and occasional employee layovers) and concluded Jinfei did not purposefully avail themselves of Illinois; the appellate court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Illinois courts have specific personal jurisdiction over the Jinfei defendants | Jinfei placed wheels into the stream of commerce with knowledge they would reach Illinois, so Illinois has specific jurisdiction | Jinfei lacked minimum contacts: transactions ended F.O.B. China, no direct sales, offices, agents, or purposeful targeting of Illinois | No — personal jurisdiction denied; dismissal affirmed |
| Whether Illinois can assert general jurisdiction over Jinfei | (Plaintiffs did not press general jurisdiction) | Jinfei not at home in Illinois (no continuous/substantial business) | No general jurisdiction asserted or found |
| Applicability of stream-of-commerce theories (Asahi/World‑Wide/J. McIntyre) | Reliance on broader stream‑of‑commerce principles (and on Russell) to show purposeful availment because products reached Illinois | Jinfei’s limited contacts (awareness of possible destination, FOB shipments, role limited to China) do not satisfy purposeful availment or targeting of Illinois | Stream‑of‑commerce insufficient here; the court distinguished Russell and found purposeful availment lacking |
| Whether the exercise of jurisdiction would comport with due process/reasonableness | Illinois is an appropriate forum to redress injury caused by nonresidents whose products enter the U.S. market | Jurisdiction would offend fair play and substantial justice because contacts are attenuated and unilateral acts by UPC/distributors brought goods to Illinois | Due process not satisfied; exercising jurisdiction would be unreasonable |
Key Cases Cited
- Russell v. SNFA, 987 N.E.2d 778 (Ill. 2013) (IL Supreme Court finding specific jurisdiction where defendant knowingly used U.S. distributors and had direct business ties to Illinois)
- International Shoe Co. v. Washington, 326 U.S. 310 (U.S. 1945) (minimum contacts standard for personal jurisdiction)
- World‑Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (U.S. 1980) (stream‑of‑commerce may support jurisdiction when defendant serves the forum market)
- Asahi Metal Industry Co. v. Superior Court, 480 U.S. 102 (U.S. 1987) (divided views on whether mere placement into stream‑of‑commerce suffices for jurisdiction)
- J. McIntyre Machinery, Ltd. v. Nicastro, 564 U.S. 873 (U.S. 2011) (plurality emphasizing targeting/intent to submit to forum authority)
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (U.S. 1985) (purposeful availment and relatedness required for specific jurisdiction)
- Walden v. Fiore, 571 U.S. 277 (U.S. 2014) (jurisdiction depends on defendant’s own contacts with the forum, not third‑party effects)
- Wiles v. Morita Iron Works Co., 530 N.E.2d 1382 (Ill. 1988) (Illinois precedent requiring awareness that final product is marketed in forum as minimal threshold)