Ford Motor Co. v. Montana Eighth Judicial Dist.
592 U.S. 351 · Supreme Court of the United States · 2021
Facts
Two residents, one in Montana and one in Minnesota, were injured or killed in accidents involving allegedly defective Ford vehicles in their respective home states. Ford, a global auto company, extensively markets, sells, and services its products, including these models, in both states, but the specific vehicles involved were originally sold outside of Montana and Minnesota. Ford argued that specific personal jurisdiction was lacking because the claims did not causally arise from its conduct in the forum state related to the specific vehicles involved.
Issue
Does specific personal jurisdiction exist over a nonresident defendant when its product causes injury in the forum state to a resident, and the defendant extensively markets and services that product model in the state, even if the specific product unit was not originally sold or manufactured there?
Holding
Yes, the connection between the plaintiffs' claims and Ford's activities in Montana and Minnesota is close enough to support specific jurisdiction. The Court affirmed the state supreme courts' decisions, finding that when a company serves a market for a product in a state and that product causes injury there to a resident, the state's courts may entertain the suit.
Rule
Specific personal jurisdiction requires that a defendant "purposefully avail itself of the privilege of conducting activities within the forum State" and that the plaintiff's claims "arise out of or relate to the defendant’s contacts" with the forum. The "relate to" prong extends beyond strict causality, allowing jurisdiction when a company systematically serves a market in a state for the very product that allegedly malfunctions and injures a resident in that state.
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