Jurisdiction

Robert Nicastro seriously injured his hand while using a metal-shearing machine manufactured by J. McIntyre Machinery, Ltd. (J. McIntyre). The accident occurred in New Jersey, but the machine was manufactured in England, where J. McIntyre was incorporated and operated. Nicastro filed suit in New Jersey state court, where the accident occurred, but J. McIntyre sought to dismiss the suit for want of personal jurisdiction.

The New Jersey Supreme Court concluded that jurisdiction was proper because the injury occurred in New Jersey; because J. McIntyre knew or reasonably should have known that its products were distributed through a nationwide distribution system that might lead to those products being sold in any of the 50 states; and because it took no reasonable steps to prevent the distribution of its products in the state. McIntyre appeals; the U.S. Supreme Court reverses.

The issue here is whether a state court can exercise jurisdiction over an entity absent from the state at the time of injury and of suit and whose activities in the state reveal no intent to invoke or benefit from the protection of its laws.

The Court notes that “[t]he rules and standards for determining when a State does or does not have jurisdiction over an absent party have been unclear because of decades-old questions left open in Asahi Metal Industry Co. v. Superior Court of Cal., Solano Cty., 480 U.S. 102 (1987).” [Slip op. 5] In that case, the Court states, “Justice Brennan’s concurrence, advocating a rule based on general notions of fairness and foreseeability, is inconsistent with the premises of lawful judicial power. This Court’s precedents make clear that it is the defendant’s actions, not his expectations, that empower a State’s courts to subject him to judgment.” [Slip op. 12] If foreseeability were the controlling criterion, the Court adds, the owner of a small Florida farm who sold crops to a large...