Ford Motor Company v. Montana Eighth Judicial District Court

141 S. Ct. 1017 (2021)


Accidents involving two of D’s vehicles are before the court. One case comes from Montana. The second from Minnesota. D moved to dismiss the two suits for lack of personal jurisdiction. D claimed the courts had jurisdiction only if D's conduct in the State had given rise to the claims. D claims that occurred only if D had designed, manufactured, or-most likely-sold in the State the particular vehicle involved in the accident. D had designed the cars in Michigan, and it had manufactured the cars in Kentucky and Canada. D had originally sold the cars at issue outside the forum States-the Explorer in Washington, the Crown Victoria in North Dakota. Only later resales and relocations by consumers had brought the vehicles to Montana and Minnesota. D claimed both the courts lacked jurisdiction. Both courts rejected D’s arguments. The courts analyzed the evidence that D advertises in the State; “has thirty-six dealerships” there; “sells automobiles and parts” to residents; and provides them with “certified repair, replacement, and recall services.” D’s conduct, said the court, encourages residents to drive Ford vehicles. When that driving causes in-state injury, the ensuing claims have enough of a tie to Ford’s activities to support jurisdiction. Whether D “designed, manufactured, or sold the vehicle” in the State, the court concluded, is “immaterial.” That the “particular vehicle” injuring someone was “designed, manufactured, and first sold” elsewhere made no difference. The totality of D's activities still had the needed connection to the allegations that a defective car caused an in-state injury. The Supreme Court granted certiorari.