In order for a state court to exercise specific jurisdiction, the suit must arise out of or relate to the defendant’s contacts with the forum. In other words, there must be an affiliation between the forum and the underlying controversy, principally, an activity or an occurrence that takes place in the forum State and is therefore subject to the State’s regulation. For this reason, specific jurisdiction is confined to adjudication of issues deriving from, or connected with, the very controversy that establishes jurisdiction.
A group of plaintiffs, most of whom are not California residents, sued Bristol-Myers Squibb Company (BMS) in California state court, alleging that the pharmaceutical company's drug Plavix had damaged their health. BMS is incorporated in Delaware and headquartered in New York, and it maintains substantial operations in both New York and New Jersey. Although it engages in business activities in California and sells Plavix there, BMS did not develop, create a marketing strategy for, manufacture, label, package, or work on the regulatory approval for Plavix in the State.The nonresident plaintiffs did not allege that they obtained Plavix from a California source, that they were injured by Plavix in California, or that they were treated for their injuries in California. The California Superior Court denied BMS's motion to quash service of summons on the nonresidents' claims for lack of personal jurisdiction, concluding that BMS's extensive activities in the State gave the California courts general jurisdiction. The Supreme Court ruled that the California court had no jurisdiction.
Did the state court have jurisdiction over the claims of non-residents?
The state court's exercise of specific jurisdiction over the nonresidents' claims violated the Fourteenth Amendment. The Fourteenth Amendment limited a state court's personal jurisdiction such that a suit had to arise out of, or relate to the, defendant's contacts with the forum. California state courts lacked specific jurisdiction over nonresidents' state-law claims alleging injuries caused by drug manufactured by the corporation, which was incorporated in Delaware and headquartered in New York, with substantial operations in New York and New Jersey. There was no adequate link between California and the claims. The nonresident consumers did not purchase or ingest the drug in California, they were not injured by the drug in California, and the fact that others were prescribed, obtained, and ingested the drug in California did not warrant specific jurisdiction over the nonresidents' claims.