Law School Case Brief
Ratliff v. Cooper Labs., Inc - 444 F.2d 745 (4th Cir. 1971)
Despite the rather obvious point that the Fifth Amendment, rather than the Fourteenth Amendment, should be the source of due process limitation upon the exercise of federal court powers, the court assumes that the incorporation of state law to confer district court amenability embraces state law as limited by federal restraints on the states themselves.
Several consumers filed an action in a federal district court in South Carolina against defendant drug manufacturing companies. One consumer was a citizen and resident of Florida and purchased and consumed the allegedly harmful drugs in Florida. Another consumer was a citizen and resident of Indiana and purchased and consumed the allegedly harmful drugs in Indiana. One drug manufacturer was a Delaware corporation with its principal place of business in Connecticut. Another drug manufacturer was a Delaware corporation with its principal place of business in New York. Plaintiff consumers' only interest in South Carolina was its 6-year statute of limitations. The district court denied the motions of the drug manufacturing companies to set aside the service of summons and to dismiss the complaint. Thus, this appeal.
Were there sufficient contacts, which satisfied the due process clause of the Fourteenth Amendment, for the federal district court in South Carolina to assert in personam jurisdiction over the parties?
The United States Court of Appeals for the Fourth Circuit concluded that it was unreasonable to require the drug manufacturers to litigate in South Carolina. Their activities, although possibly sufficient to constitute a presence in the state, were minimal. They did not maintain offices, warehouses, or bank accounts in the state, and they did not advertise in directories in the state. Nor were any of the plaintiff consumers residents of the state. Thus, the court held that principles of due process required a firmer foundation for in personam jurisdiction.
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