J. McIntyre Machinery, Ltd. v. Nicastro

Facts

Robert Nicastro seriously injured his hand while using a metal-shearing machine. The accident happened in New Jersey. J. McIntyre Machinery, Ltd. (J. McIntyre) made the machine in England, where it is incorporated and operates. Nicastro sued J. McIntyre in a New Jersey state court. J. McIntyre had never marketed goods in New Jersey or shipped them there. At oral argument, Nicastro's counsel stressed three facts. First, an independent company agreed to sell J. McIntyre's machines in the United States. J. McIntyre sold to no U.S. buyer beyond that distributor, and no one alleged the distributor was under its control. Second, J. McIntyre officials attended annual scrap recycling conventions to advertise the machines alongside the distributor. The conventions took place in various States, but never in New Jersey. Third, no more than four machines, including the one that injured Nicastro, ended up in New Jersey. The record suggests only one. The New Jersey Supreme Court added that J. McIntyre held United States and European patents on its technology, that the distributor structured its advertising and sales efforts according to J. McIntyre's direction and guidance whenever possible, and that at least some machines were sold to the distributor on consignment. The British manufacturer had no office in New Jersey, paid no taxes and owned no property there, and neither advertised in the State nor sent employees to it.

Issues

1. Does the Due Process Clause let a New Jersey state court exercise jurisdiction over an English manufacturer whose products reached New Jersey through an independent U.S. distributor, when the manufacturer never targeted New Jersey itself?
2. Can the "stream of commerce" idea, resting on a manufacturer's ability to foresee that its goods will be sold in the forum State, support jurisdiction without the defendant's purposeful availment of that State?

Holding

The New Jersey courts could not exercise jurisdiction over J. McIntyre. The plurality found no purposeful availment of New Jersey, since the facts may reveal an intent to serve the U.S. market but do not show purposeful availment of New Jersey. Justice Breyer, joined by Justice Alito, concurred in the judgment on narrower grounds: on the facts found, a single isolated sale did not suffice under precedent.