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J. McIntyre Mach., Ltd. v. Nicastro

Supreme Court of the United States

January 11, 2011, Argued; June 27, 2011, Decided

No. 09-1343

Case Summary

Procedural Posture

Petitioner British manufacturer moved to dismiss respondent consumer's products-liability suit, arguing lack of personal jurisdiction. Under the "stream-of-commerce" doctrine, the Supreme Court of New Jersey held that the Fourteenth Amendment's Due Process Clause was not violated by the New Jersey court's exercise of jurisdiction. Certiorari was granted.

Overview

In products-liability cases, it was a defendant's purposeful availment that made jurisdiction consistent with traditional notions of fair play and substantial justice. The transmission of goods permitted the exercise of jurisdiction only where the defendant targeted the forum; generally, it was not enough that it might have predicted its goods would reach the forum State. The manufacturer directed marketing and sales efforts at the U.S., but the question was whether the New Jersey state court had the authority to exercise jurisdiction; thus, it was the manufacturer's purposeful contacts with New Jersey, not with the U.S., that alone were relevant. A distributor sold the products, the manufacturer's officials attended trade shows in several States but not in New Jersey, and up to four machines ended up in New Jersey. The manufacturer had no office in New Jersey; it neither paid taxes nor owned property there; and it neither advertised in, nor sent any employees to, the State. It did not have a single contact with New Jersey short of the product in question ending up in New Jersey. The Supreme Court of New Jersey's holding was error.

Outcome

The Court reversed the Supreme Court of New Jersey's judgment finding personal jurisdiction over the manufacturer. 6-3 Decision; 1 Concurrence; 1 Dissent.

LexisNexis® Headnotes

 

 

Civil Procedure > ... > In Rem & Personal Jurisdiction > In Personam Actions > Due Process

Civil Procedure > ... > In Rem & Personal Jurisdiction > In Personam Actions > Purposeful Availment

Constitutional Law > ... > Fundamental Rights > Procedural Due Process > Scope of Protection

HN1  Due Process

Due process protects a defendant's right not to be coerced except by lawful judicial power. As a general rule, the exercise of judicial power is not lawful unless the defendant purposefully avails itself of the privilege of conducting activities within the forum State, thus invoking the benefits and protections of its laws.

 

Civil Procedure > ... > In Rem & Personal Jurisdiction > In Personam Actions > Due Process

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

Constitutional Law > ... > Fundamental Rights > Procedural Due Process > Scope of Protection

HN2  Due Process

The Due Process Clause protects an individual's right to be deprived of life, liberty, or property only by the exercise of lawful power. This is no less true with respect to the power of a sovereign to resolve disputes through judicial process than with respect to the power of a sovereign to prescribe rules of conduct for those within its sphere. As a general rule, neither statute nor judicial decree may bind strangers to the State.

 

Civil Procedure > ... > In Rem & Personal Jurisdiction > In Personam Actions > Due Process

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

Civil Procedure > ... > In Rem & Personal Jurisdiction > In Personam Actions > Purposeful Availment

HN3  Due Process

A court may subject a defendant to judgment only when the defendant has sufficient contacts with the sovereign such that the maintenance of the suit does not offend traditional notions of fair play and substantial justice. Free-form notions of fundamental fairness divorced from traditional practice cannot transform a judgment rendered in the absence of authority into law. As a general rule, the sovereign's exercise of power requires 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, though in some cases, as with an intentional tort, the defendant might well fall within the State's authority by reason of his attempt to obstruct its laws.

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564 U.S. 873 ; 131 S. Ct. 2780 ; 180 L. Ed. 2d 765 ; 2011 U.S. LEXIS 4800 ; 79 U.S.L.W. 4684; CCH Prod. Liab. Rep. P18,653; 22 Fla. L. Weekly Fed. S 1295

J. McINTYRE MACHINERY, LTD., Petitioner v. ROBERT NICASTRO, individually and as administrator of the ESTATE OF ROSEANNE NICASTRO

Prior History:  [1] ON WRIT OF CERTIORARI TO THE SUPREME COURT OF NEW JERSEY.

Nicastro v. McIntyre Machinery America, Ltd., 201 N.J. 48, 987 A.2d 575, 2010 N.J. LEXIS 19 (2010)

Disposition: Reversed.