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Bristol-Myers Squibb Co. v. Superior Court of CA

(2017)

Supreme Court of the United States - 137 S. Ct. 1773

tl;dr:

Litigation must arise out of or relate to the defendant's forum state conduct for the state to validly assert specific personal jurisdiction.

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Case Summary

Bristol-Myers Squibb Co. v. Superior Court of California centered around a disagreement over personal jurisdiction between a pharmaceutical company, BMS, and hundreds of plaintiffs who claimed BMS's drug Plavix caused them injuries. Most plaintiffs were not from California and their Plavix-related issues did not occur there. BMS was based in Delaware and New York and did not work on Plavix in California. BMS argued they had no significant connection to California and being subject to jurisdiction there would be unfair.

The Supreme Court agreed and reversed California's decision, stating that the nonresident plaintiffs' claims did not connect to BMS's California contacts for specific jurisdiction. The Court dismissed arguments that BMS's nationwide distribution of Plavix and other California connections mattered in this case.

This decision clarified the boundaries of specific jurisdiction for out-of-state defendants based on their connections with the state where the case is held. The Court reinforced that specific jurisdiction requires a direct link between the defendant's state contacts and the plaintiff's claims. Mere similarities between resident and nonresident plaintiffs' claims are not enough.

ICRAIssue, Conclusion, Rule, Analysis for Bristol-Myers Squibb Co. v. Superior Court of CA

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Facts & HoldingBristol-Myers Squibb Co. v. Superior Court of CA case brief facts & holding

Facts:Bristol-Meyers Squibb Co ("BMS") is a drug manufacturer incorporated in...

Holding:There are two kinds of personal jurisdiction which may be...

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Bristol-Myers Squibb Co. v. Superior Court of CA | Case Brief DeepDive
Majority opinion, author: Justice ALITO delivered the opinion of the Court.
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The US Supreme Court overturned the California Supreme Court's decision to hear non-residents' claims against Bristol-Myers Squibb Company (BMS) for injuries caused by the drug Plavix, stating that BMS's connections to California were not sufficient to establish specific jurisdiction. The California Superior Court had previously denied BMS's motion, citing general jurisdiction over BMS due to its extensive activities in California. However, the California Supreme Court found that general jurisdiction was lacking under Daimler AG v. Bauman, but specific jurisdiction existed over the nonresidents' claims against BMS. The US Supreme Court found that the California Supreme Court's "sliding scale approach" to specific jurisdiction was not consistent with established legal precedents and resembled general jurisdiction. The nonresident plaintiffs' claims do not involve harm in California or to California residents, and therefore, the California courts cannot claim specific jurisdiction. The Supreme Court's decision does not prevent out-of-state plaintiffs from joining together in a consolidated action in states that have general jurisdiction over the defendant.

Dissenting opinion, author: Justice SOTOMAYOR, dissenting.
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The Supreme Court ruled that Bristol-Myers Squibb can be sued in California by non-residents if their claims are joined with identical claims brought by California residents. The Court found that the company had purposefully availed itself of California's market and that the non-residents' claims "relate to" its in-state conduct. The exercise of jurisdiction over the non-residents' claims is reasonable, as it allows for a consolidated proceeding in one State under shared counsel, which minimizes costs and maximizes recoveries. However, Justice Sotomayor dissented, arguing that this rule will make it difficult to bring a nationwide mass action in state court against defendants who are "at home" in different states.

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