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

Ford Motor Company (Ford) (defendant) marketed, sold, and serviced vehicles, including Explorers and Crown Victorias, in both Montana and Minnesota. Montana resident Markkaya Gullett (plaintiff) was killed while driving her Ford Explorer in Montana. Minnesota resident Adam Bandemer (plaintiff) was severely injured while riding in a Ford Crown Victoria in Minnesota. Gullett’s estate sued Ford in Montana state court, and Bandemer sued Ford in Minnesota state court. Both lawsuits alleged that the vehicles were defective. Ford moved to dismiss both cases, arguing that the state courts lacked personal jurisdiction over it. Ford was a Delaware corporation that was headquartered in Michigan. Ford had not designed, manufactured, or sold either allegedly defective vehicle in either Montana or Minnesota. Ford had sold both vehicles in other states, and the vehicles were resold before being involved in the accidents. Both state trial courts ruled that they could assert personal jurisdiction over Ford, and both state supreme courts affirmed those rulings. The United States Supreme Court joined the cases and granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Kagan, J.)

Concurrence (Alito, J.)

Concurrence (Gorsuch, J.)

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Key Terms

  • Fourteenth Amendment Due Process ClauseThe provision set forth at Amendment XIV, Section 1 of the United States Constitution prohibiting states from depriving any person of life, liberty, or property by means that are arbitrary or fundamentally unfair.
  • Minimum ContactsThe extent and quality of connections—which must meet a standard of fair play and substantial justice—that a nonresident defendant must have with the forum state in order for a court in that state to exercise personal jurisdiction over such defendant.
  • Personal JurisdictionThe power of a court to adjudicate the rights of a particular person or entity.
  • General JurisdictionThe court’s ability to hear cases related to a party, regardless of whether the harm has any connection to the forum.
  • Specific JurisdictionPersonal jurisdiction over a defendant that is derived from the defendant’s activities in a state, giving the court power to adjudicate claims arising out of those activities; specific jurisdiction only exists if the defendant has sufficient minimum contacts to satisfy due process.
  • But-For CauseAlso referred to as “cause in fact” or “actual cause,” an act or omission in the absence of which a particular result could not have occurred.

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