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Ford Motor Co. v. Montana Eighth Judicial District Court

592 U.S. __, 141 S.Ct. 1017, 209 L.Ed.2d 225 (2021)

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Ford Motor Co. v. Montana Eighth Judicial District Court

United States Supreme Court

592 U.S. __, 141 S.Ct. 1017, 209 L.Ed.2d 225 (2021)

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Facts

Ford Motor Company (defendant) is a Delaware corporation headquartered in Michigan. Ford advertises, sells, and services its vehicles worldwide and encourages a resale market for used Ford vehicles. In 2016 and 2018, plaintiffs sued Ford in Minnesota and Montana state courts, asserting claims based on accidents in those states in which allegedly defective Ford vehicles injured or killed state residents. Ford moved to dismiss the actions for lack of personal jurisdiction. Ford asserted that jurisdiction was proper only if Ford’s forum-state activities were causally linked to the plaintiffs’ claims, or in other words, only if Ford’s forum-state activities included designing, manufacturing, or selling the specific vehicles involved in the accidents. Ford claimed that jurisdiction was lacking because the vehicles had been designed, manufactured, and sold outside Minnesota and Montana and only ended up in those states through resales and relocation. Both trial courts ruled against Ford, and Ford appealed. In the Montana action, Ford styled its appeal as a request for the Montana Supreme Court to exercise supervisory control over the Montana Eighth Judicial District Court and dismiss the action. The state supreme courts rejected Ford’s personal-jurisdiction argument and affirmed the lower courts’ decisions. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Kagan, J.)

Concurrence (Gorsuch, J.)

Concurrence (Alito, J.)

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