Ford Motor Co. v. Montana Eighth Judicial District Court

592 U.S. 351 (2021)

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Ford Motor Co. v. Montana Eighth Judicial District Court

United States Supreme Court
592 U.S. 351 (2021)

  • Written by Liz Nakamura, JD
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Facts

Automaker Ford Motor Company (Ford) (defendant) was incorporated in Delaware and headquartered in Michigan. Ford sold, marketed, advertised, and serviced new and used Ford vehicles nationwide. Montana resident Markkaya Gullett was killed in a car crash caused by a defect in her Ford Explorer. Minnesota resident Adam Bandemer (plaintiff) suffered injuries caused by a defect in his friend’s Ford Crown Victoria. Gullett’s estate (plaintiff) and Bandemer brought products-liability actions against Ford in Montana and Minnesota respectively. Ford moved to dismiss both suits. It argued that the state courts lacked personal jurisdiction over Ford because the relevant vehicles were not designed, manufactured, or originally sold in the forum states, and consequently, there was no causal connection between the plaintiffs’ claims and Ford’s instate activities. The vehicles were in Montana and Minnesota only because of consumer resales. The state trial courts rejected Ford’s argument, finding that Ford had sufficient connections with their states to support personal jurisdiction. The Montana Supreme Court and Minnesota Supreme Court affirmed, and the United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Kagan, J.)

Concurrence (Alito, J.)

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