October 27, 2013

Asahi Metal Industry Co. v. Superior Court | Case Brief | 480 U.S. 102, 107 S.Ct. 1026, 94 L.Ed.2d 92 (1987) - US Supreme Court

FACTS: Mr. Zuchner was driving his Honda motorcycle when it collided w/ a tractor.  He was seriously injured and his wife who was a passenger was killed.  He filed a product liability action in the Superior Court of the State of California in and for the County of Solano.  He alleged the accident was caused by a an explosion and sudden loss of air in the rear tire and claimed the tire, its, tube, and sealant were defective.  Zurchner's complaint among other things named Chen Shin Rubber Industrial Company which manufactured the tube.  In response Chen Shin filed a cross-complaint seeking indemnification from Asahi which manufactured the tubes valve assembly.  Zurchner's complaint was settled and dismissed but the action between Chen Shin and Asahi remained.

ISSUE: Does "the mere awareness on the part of a foreign defendant that the components it manufactured, sold, and delivered outside the US would reach the forum state in the stream of commerce constitute "minimum contacts" between the defendant and the forum state such that the exercise of jurisdiction  "does not offend `traditional notions of fair play and substantial justice'?"

HOLDING: No

RATIONALE:

IIA - "The placement of a product into the stream of commerce, w/out more, is not an act of the defendant purposefully directed toward the forum State." (262)  Awareness that the stream of commerce may place the product into the forum State does not convert the act of placing the product into the stream into an act purposefully directed at the forum State.

IIB - This regards the issue of traditional notions of fair play.  "The unique burdens placed upon one who must defend oneself in a foreign legal system should have significant weight  in assessing the reasonableness of stretching the long arm  of personal jurisdiction over national boundaries." (263) The slight interests of the plaintiff do not justify the burden of travel necessary for the defendant to go to CA to defend its actions.  (top 265)

III - Dissent of Brennan, White, Marshall, Blackmun for IIA
They argue that as long as a participant is aware that the process of the stream of commerce may cause the product in question to be marketed in the sorum state then they should be aware of the possibility of litigation in that state.

Dissent of Stevens, White, Blackmun also for IIA
    
1) Examination of minimum contacts is not necessary to determine if personam jurisdiction is constitutional. The case fits within the rule that "minimum requirements inherent in the concept of `fair play and substantial justice' may defeat the reasonableness of jurisdiction even if the defendant has purposefully engaged in forum activities." (267)


2) The court assumes that an unwavering line can be drawn between "mere awareness" that the product will reach the forum's market and "purposeful availment" of the forum's market.  Shipping over 100,000 units annually can constitute "purposeful availment." (268)