Asahi Metal Industry Co. v. Superior Court of Cal., Solano Cty.
94 L. Ed. 2d 92 · Supreme Court of the United States · 1987
Facts
A California resident was injured in a motorcycle accident allegedly caused by a defective tire tube. The Taiwanese manufacturer of the tube, Cheng Shin, sought indemnification from Asahi Metal Industry Co., Ltd., a Japanese company that manufactured the valve assembly and sold it to Cheng Shin in Taiwan. Asahi had no direct contacts with California, but was aware its components might end up there.
Issue
Does a foreign manufacturer's mere awareness that its components, sold outside the U.S., would reach a forum state in the stream of commerce constitute sufficient 'minimum contacts' for personal jurisdiction under the Due Process Clause?
Holding
No. The Supreme Court reversed the California Supreme Court, holding that California courts could not exercise personal jurisdiction over Asahi because Asahi lacked sufficient minimum contacts with the state and the exercise of jurisdiction would be unreasonable and unfair.
Rule
For personal jurisdiction, minimum contacts must arise from an action by the defendant purposefully directed toward the forum state. Placing a product into the stream of commerce, without more, is not enough; a defendant's mere awareness that its product may enter the forum state does not convert this into purposeful availment. Additionally, the exercise of jurisdiction must be reasonable, considering the burden on the defendant, the forum state's interests, and the plaintiff's interest in obtaining relief.
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