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- 141 S. Ct. 1017
Contributed by Pilea
Ford manufactured two cars with auto defects which caused severe injuries in different states from the state the cars were sold in. Because Ford had substantial contacts with those states, they are subject to jurisdiction in those states.
Issue
Can Ford be subject to personal jurisdiction by a forum state even if the vehicle that caused the accidents in question was not originally sold in that forum state?
Conclusion
Yes. Ford is subject to the jurisdiction of the forum states, because the company had substantial contacts with the forum states.
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Rule
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Analysis
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Facts
- One victim (Markkaya Gullett) was driving a Ford Explorer in Montana when the tread separated from the rear tire. the car spun out, rolled into a ditch, and came to a rest upside down, and the victim died.
- Another victim (Adam Bandemer) was a passenger in a Ford Crown Victoria in Minnesota that landed in a ditch after rear-ending a snow plow. His air bag failed to deploy, and he suffered serious brain damage.
- The defendant/petitioner (Ford) is a Delaware corporation headquartered in Michigan. Both cars were designed in Michigan. The Explorer was manufactured in Kentucky, and originally sold in Washington. The Crown Victoria was manufactured in Canada and originally sold in North Dakota
- Ford markets, advertises, resells, services, and repairs its vehicles (including the models at issue) extensively in both Montana and Minnesota.
- Each of the two plaintiffs sued in MN & MT, respectively.
- The lower courts found in favor of the plaintiffs.
- The supreme courts of the two states affirmed in favor of plaintiffs.
- Ford appeals to SCOTUS
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Holding
- Hey! This is the holding for Pennoyer v. Neff. It probably isn't the holding for the brief you're looking at. Join LSD+ for full access.
- A named property within the court's jurisdiction is attached to satisfy an unrelated claim, despite the owner of said property being a non-resident of the state.
- A named property within the court's jurisdiction is attached as the basis for the suit (e.g., to quiet title), despite the owner of said property being a non-resident of the state.
- An individual is sued who is a resident of the state, or who has been served with process while physically located within the state.
- jurisdiction - Neff is neither a resident, nor was served while within the state. Service by publication may be valid for an
- proceeding, where the owner would be made aware of the suit due to their property being seized, but not for
- jurisdiction - the action was on the basis of a suit to receive payment owed, and did not relate directly to a property within the state.
- jurisdiction, as the Oregon property was not attached to the initial suit, but rather was added in after the suit happened - note that Neff did not even purchase the property until after the suit had concluded.
- Accordingly, the Oregon court did not have jurisdiction over the initial suit between Neff and his lawyer.
- Enforcement of a judgment without jurisdiction denies due process!
- Additionally, although judgments rendered by other states are entitled to full faith and credit, if that state did not have jurisdiction to render the judgment, it loses such entitlement.
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