J. McIntyre Machinery, Ltd. v. Nicastro

180 L. Ed. 2d 765 · Supreme Court of the United States · 2011

Facts

Robert Nicastro was injured in New Jersey by a metal-shearing machine manufactured in England by J. McIntyre Machinery, Ltd. J. McIntyre sold its machines to an independent U.S. distributor and attended trade shows in other states, but had no office, property, employees, or advertising in New Jersey, and only a few machines ended up there. The New Jersey Supreme Court asserted jurisdiction based on a "stream-of-commerce" theory, finding J. McIntyre knew its products were distributed nationwide.

Issue

Can a state court exercise personal jurisdiction over a foreign manufacturer whose product caused injury in the state, when the manufacturer did not purposefully target that state but knew its products entered a nationwide distribution system?

Holding

No. The Supreme Court reversed the New Jersey Supreme Court's decision, holding that New Jersey lacked personal jurisdiction over J. McIntyre because the manufacturer did not purposefully avail itself of the privilege of conducting activities within New Jersey.

Rule

For personal jurisdiction, a defendant must purposefully avail itself of the privilege of conducting activities within the forum state, thereby invoking its benefits and protections. Merely placing a product into the stream of commerce with the expectation it might reach the forum state is insufficient; the defendant must have targeted the forum state.

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Case brief last reviewed 2026-05-01. Prepared by CaseReader from the published opinion.