Ford Motor Co. v. Montana Eighth Judicial District Court

Facts

Ford is a Delaware-incorporated, Michigan-headquartered automaker that distributes over 2.5 million vehicles a year to more than 3,200 dealerships, advertises nationwide, and supports owners with parts, service, and a resale market. Two crashes produced the suits. The cars involved, a 1996 Explorer and a 1994 Crown Victoria, had been designed in Michigan, built in Kentucky and Canada, and first sold in Washington and North Dakota. Only later resales and relocations by consumers brought them to Montana and Minnesota. In Montana, Markkaya Gullett's Explorer threw a rear-tire tread, rolled into a ditch, and killed her; her estate's representative sued Ford for design defect, failure to warn, and negligence. In Minnesota, passenger Adam Bandemer was in a friend's Crown Victoria that rear-ended a snowplow; his air bag failed to deploy and he suffered serious brain damage. He sued for products liability, negligence, and breach of warranty. Each accident happened in the forum State, each victim was a resident, and Ford had advertised, sold, and serviced those very models there for many years.

Issues

1. Does specific jurisdiction require a strict causal link between the defendant's forum contacts and the plaintiff's claims?
2. When a company serves a State's market for a product and that product malfunctions in the State injuring a resident, may the State's courts hear the suit even though the particular item was designed, manufactured, and first sold elsewhere?

Holding

Ford conceded purposeful availment of Montana's and Minnesota's markets. The resident-plaintiffs' suits, based on in-state accidents involving models Ford had advertised, sold, and serviced there for many years, relate to those contacts closely enough to support specific jurisdiction, even though the particular cars were first sold elsewhere.