Asahi Metal Industry Co., Ltd. v. Superior Court
702 P.2d 543 · California Supreme Court · 1985
Facts
In 1978, Gary Zurcher was severely injured and his wife, Ruth Ann Moreno, was killed in a motorcycle accident on a California highway, allegedly due to a defective tire. Zurcher, a California resident, filed a products liability action against Cheng Shin Rubber Industrial Co., Ltd., the Taiwanese manufacturer of the tire tube. Cheng Shin, in turn, filed a cross-complaint seeking indemnity from Asahi Metal Industry Co., Ltd., the Japanese manufacturer of the tube’s valve assembly. Asahi sold 1,350,000 valve assemblies to Cheng Shin between 1978 and 1982, knowing that Cheng Shin made 20 percent of its United States sales in California. Asahi had no direct sales, offices, or agents in California, but its valve assemblies were incorporated into tubes sold in the state.
Procedural history
Gary Zurcher filed a products liability action in California against Cheng Shin. Cheng Shin then filed a cross-complaint for indemnity against Asahi. Asahi moved to quash service of summons, which the trial court denied, finding sufficient minimum contacts and that jurisdiction was fair and reasonable. Asahi then sought a writ of mandate from this court to compel the trial court to grant its motion.
Issue
Can California constitutionally exercise personal jurisdiction over a manufacturer of component parts who made no direct sales in California but had knowledge that a substantial number of its parts would be incorporated into finished products sold in the state?
Holding
Yes, California can constitutionally exercise personal jurisdiction over Asahi, as the trial court's order denying Asahi's motion to quash service of summons was proper.
Rule
Personal jurisdiction requires minimum contacts with the forum state such that maintaining the suit does not offend traditional notions of fair play and substantial justice. This minimum contacts test is satisfied when a manufacturer delivers its products into the stream of commerce with the expectation that they will be purchased by consumers in the forum state, thereby purposefully availing itself of the forum's market and laws. Additionally, jurisdiction must be fair and reasonable, balancing the inconvenience to the defendant against the plaintiff's and state's interests. California has a substantial interest in protecting its consumers, ensuring safety standards, and avoiding multiple, conflicting adjudications.
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