What comes next?
On March 25, 2021, the U.S. Supreme Court broadened the reach of specific personal jurisdiction by finding that Ford Motor Co. can be sued in Montana and Minnesota for vehicles that were “designed, manufactured, and first sold” out of state. The Supreme Court held that “[w]hen a company … serves a market for a product in a State and that product causes injury in the State to one of its residents, the State’s courts may entertain the resulting suit.” The decision could mark the beginning of new cases where the underlying claims only “relate to” a defendant’s activities in the state, or the decision could further confuse lower courts that try to determine what activity relates to the underlying claims.
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On March 25, 2021, the Supreme Court held in
Ford Motor
Company v. Montana Eighth Judicial District Court that Montana
and Minnesota courts could exercise jurisdiction over the global
auto manufacturer for certain in-state vehicle accidents, even if
Ford sold, designed, and manufactured the allegedly defective
automobiles outside those forums.
1 The
Ford
decision sparked immediate questions about the direction of the
Court s personal jurisdiction jurisprudence, especially after a
decade of decisions restricting the exercise of jurisdiction over
out-of-state defendants. Does
Ford signal a return to the
days of expansive jurisdiction or was it simply a tried-and-true
application of existing principles? In other words, how worried