Bristol-Myers Squibb Co. v. Superior Court of Cal., San Francisco Cty.
582 U.S. 255 · Supreme Court of the United States · 2017
Facts
Bristol-Myers Squibb (BMS), a pharmaceutical company incorporated in Delaware and headquartered in New York, manufactures and sells the drug Plavix. BMS did not develop, market, or manufacture Plavix in California, but it did sell the drug there, generating over $900 million in sales between 2006 and 2012. Over 600 plaintiffs, including 86 California residents and 592 nonresidents from 33 other states, sued BMS in California, alleging injuries from Plavix. The nonresident plaintiffs did not obtain Plavix, suffer injury, or receive treatment in California. Their claims were based on state law, including products liability and negligent misrepresentation.
Procedural history
Plaintiffs filed suit in California Superior Court, which denied BMS's motion to quash service for nonresidents' claims, finding general jurisdiction. After *Daimler*, the California Supreme Court directed the Court of Appeal to reconsider, which then found no general jurisdiction but specific jurisdiction. The California Supreme Court affirmed the finding of specific jurisdiction, leading to the U.S. Supreme Court granting certiorari.
Issue
Does the Due Process Clause of the Fourteenth Amendment permit California courts to exercise specific personal jurisdiction over claims brought by nonresident plaintiffs against a pharmaceutical company, where the claims do not arise from the company's activities within California?
Holding
No, the Due Process Clause of the Fourteenth Amendment does not permit California courts to exercise specific personal jurisdiction over the nonresident plaintiffs' claims against Bristol-Myers Squibb. The California Supreme Court's judgment is reversed.
Rule
For a state court to exercise specific jurisdiction, there must be an "affiliation between the forum and the underlying controversy," meaning the suit must "aris[e] out of or relat[e] to the defendant's contacts with the forum." Specific jurisdiction is confined to issues deriving from, or connected with, the very controversy that establishes jurisdiction. A defendant's general connections with the forum are insufficient if the claims are unrelated to those contacts, and a "sliding scale approach" that relaxes the connection requirement based on extensive unrelated forum contacts is impermissible. The primary concern is the burden on the defendant and the territorial limitations on state power, reflecting principles of interstate federalism.
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