Asahi Metal Indus. Co. v. Superior Court of Cal.

Case Summary

Procedural Posture

On writ of certiorari to the Supreme Court of California, petitioner, a Japanese corporation, sought review of a decision that California courts had personal jurisdiction over it on the claim of respondent, a Taiwanese corporation, for indemnification in a products liability action where the defect involved a component manufactured by petitioner and sold to respondent, who had it assembled in respondent's factory in Taiwan.

Overview

Petitioner, a Japanese corporation, manufactured a valve that was sold to respondent, a Taiwanese corporation, who used it in the manufacture of a motorcycle tire. When the tire exploded while the motorcycle owner was driving it in California, the driver filed a products liability action against respondent, who filed a cross-complaint for indemnity against petitioner. The trial court denied petitioner's motion to quash the service of summons, the appellate court reversed, and the state supreme court reversed the appellate court. On certiorari, the Supreme Court held that the mere fact that petitioner knew that some of its component parts would be used in products that would be sold in the state did not provide the necessary minimum contacts for the state to exercise personal jurisdiction over petitioner, since petitioner did nothing to purposely avail itself of the privilege of conducting activities in the state. Therefore, since there were no minimum contacts, the state was estopped by Fourteenth Amendment due process from exercising personal jurisdiction over petitioner. The Court reversed the judgment of the state supreme court and remanded the case.

Outcome

The Court reversed the judgment and remanded the case, since petitioner conducted no activities in the state and thus did not have the necessary minimum contacts with the state that would allow the state to exercise personal jurisdiction over petitioner.

LexisNexis^® Headnotes

Civil Procedure > ... > In Rem & Personal Jurisdiction > In Personam Actions > General Overview

HN1  In Rem & Personal Jurisdiction, In Personam Actions

California's long-arm statute authorizes the exercise of jurisdiction on any basis not inconsistent with the constitution of the state or of the United States. Cal. Code Civ. Proc. § 410.10.

Civil Procedure > ... > Jurisdiction > In Rem & Personal Jurisdiction > Constitutional Limits

Constitutional Law > ... > Fundamental Rights > Procedural Due Process > General Overview

Civil Procedure > ... > Jurisdiction > In Rem & Personal Jurisdiction > General Overview

Civil Procedure > ... > In Rem & Personal Jurisdiction > In Personam Actions > General Overview

Civil Procedure > ... > In Rem & Personal Jurisdiction > In Personam Actions > Minimum Contacts

HN2  In Rem & Personal Jurisdiction, Constitutional Limits

The Due Process Clause of U.S. Const. amend. XIV limits the power of a state court to exert personal jurisdiction over a nonresident defendant. The constitutional touchstone of the determination whether an exercise of personal jurisdiction comports with due process remains whether the defendant purposefully established minimum contacts in the forum state.

Civil Procedure > ... > Jurisdiction > In Rem & Personal Jurisdiction > Constitutional Limits

Civil Procedure > ... > In Rem & Personal Jurisdiction > In Personam Actions > General Overview

HN3  In Rem & Personal Jurisdiction, Constitutional Limits

Minimum contacts must have a basis in some act by which the defendant purposefully avails itself of the privilege of conducting activities within the forum state, thus invoking the benefits and protections of its laws. Jurisdiction is proper where the contacts proximately result from actions by the defendant himself that create a "substantial connection" with the forum state.