Ford Motor Co. v. Mont. Eighth Judicial Dist. Court - 2019 MT 115, 395 Mont. 478, 443 P.3d 407

Rule:

If the sale of a product of a manufacturer or distributor is not simply an isolated occurrence, but arises from the efforts of the manufacturer or distributor to serve directly or indirectly, the market for its product in other States, it is not unreasonable to subject it to suit in one of those States if its allegedly defective merchandise has there been the source of injury. Where a plaintiff alleges a nonresident defendant, acting outside of the forum, placed a product into the stream of commerce that ultimately caused harm in the forum, the flow of a manufacturer's products into the forum may bolster an affiliation germane to specific jurisdiction. Therefore, when the defendant purposefully avails itself of the privilege of conducting activities in a specific forum by placing a product into the stream of commerce, the plaintiff's claims will relate to the defendant's forum-related activities as long as the connection between the defendant's in-state conduct and the plaintiff's claim is sufficient enough to not offend due process.

Facts:

Markkaya Jean Gullett, a Montana resident, drove a 1996 Ford Explorer. Ford did not design or manufacture the Explorer in Montana. Ford assembled the Explorer in Kentucky and sold it for the first time to a dealer in Washington. Over ten years later, the Explorer was resold and registered in Montana. In 2015, as Gullett drove the Explorer on the interstate in Montana, one of the Explorer's tires suffered a tread/belt separation. The vehicle lost stability, rolled into a ditch, and came to rest upside down. Gullett died at the scene. Gullett's personal representative, Charles Lucero filed the present suit against Ford in Montana state district court on behalf of Gullett and her heirs, alleging three claims against Ford: strict liability for design defect, strict liability for failure to warn, and negligence. Furthermore, Lucero sought compensatory and punitive damages. Defendant Ford moved to dismiss, arguing that Montana did not have specific personal jurisdiction over Ford regarding Lucero's claims and specifically reasoning that there was no link between Ford's Montana contacts and Lucero's claims. The District Court disagreed and ultimately concluded it had specific personal jurisdiction over Ford. Ford appealed. 

Issue:

Did Montana have specific personal jurisdiction over Ford regarding Lucero's claims? 

Answer:

Yes.

Conclusion:

The Court held that Montana had specific personal jurisdiction over Ford, because Ford’s purposeful interjections into Montana were extensive as it delivered its vehicles and parts into the stream of commerce with the expectation that Montana consumers would purchase them. Moreover, the Court held that Ford did not represent that it was burdened by defending in Montana. According to the Court, Montana had a strong interest in adjudicating the dispute, the controversy could be efficiently resolved in Montana, and while alternative forums existed, those forums were less convenient considering the fact that the accident occurred in Montana.