The Supreme Court recently released a unanimous 8-0 ruling that will help individuals injured by defective and dangerous products overcome jurisdictional hurdles in filing a lawsuit. The case, Ford Motor Co. v. Montana Eighth Judicial District Court, involved two car accidents – one occurring in Montana and another in Minnesota. The first accident involved a driver traveling near her home when her Ford Explorer’s tread suddenly separated from a read tire. The second incident stemmed from a Ford vehicle with an air bag that failed to deploy. The consolidated lawsuits were each brought in the states where the respective accidents occurred. Neither car involved in the crashes was first sold in Montana or Minnesota, nor were the cars designed or manufactured in those states.
In order to bring a lawsuit in a specific court, that court must have jurisdiction. There are two types of jurisdiction—general and specific. A state court has general jurisdiction when a defendant is “at home” in the state. A defendant can be “at home” in a state when its principal office is located there or it is incorporated in the state, for example.
A state court can exercise specific jurisdiction when a defendant “deliberately ‘reach[es] out beyond’ its home—by, for example, ‘exploi[ting] a market’ in the forum State.” In the Ford case, Ford argued that because the two vehicles were sold in Washington and North Dakota and manufactured in Kentucky and Canada, Montana and Minnesota did not have jurisdiction. Because Montana and Minnesota had no causal link to the company, Ford argued, it could not be sued in those states’ courts.
The Supreme Court was quick to reject Ford’s arguments, noting that while the benchmark for proving specific jurisdiction may narrow the claims that are heard in state courts, “the most common formulation of the rule demands that the suit ‘arise out of or relate to the defendant’s contacts with the forum.’” Thus, though the two cars were sold and manufactured elsewhere, because Ford “does substantial business in Montana and Minnesota” that “deliberately extend[s]” to both states, the Supreme Court held that the Montana and Minnesota had specific jurisdiction over the claims.
The effect of the Supreme Court’s holding is to level the playing field amongst injured individuals and the corporations that harmed them. As the Supreme Court pointed out, corporations that do extensive business in a state “enjoy the benefits and protection of [the state] laws.” In turn, the corporations have an obligation to ensure their products are safe for citizen use.
The attorneys at Regan Zambri Long have devoted their practice to representing injured people, including victims of defective and dangerous products. If you or someone you know has been injured by a defective and dangerous product, contact us today for a no-cost consultation.