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Gray v. American Radiator & Standard Sanitary Corp.

Supreme Court of Illinois
22 Ill.2d 432, 176 N.E.2d 761 (1961)

Gray v. American Radiator & Standard Sanitary Corp.


Phyllis Gray (plaintiff) was injured by a water heater that exploded. Gray bought the water heater in Illinois and brought suit in Illinois against Titan Valve Manufacturing Company (Titan) (defendant), the company that had negligently made the water heater’s safety valve. Titan was served with the complaint in Ohio. The company did not do business in Illinois, had no agent present in Illinois, and actually sold the safety valves to a third party in Pennsylvania where the valve was attached to the water heater. An Illinois jurisdiction statute stated that a nonresident who commits a tortious act in Illinois submits to the jurisdiction of Illinois courts. Titan filed a motion to dismiss, arguing that the statute violated due process of law by placing Titan under Illinois jurisdiction even though the company’s only contact with the state was Gray’s injury. The court granted the motion to dismiss and Gray appealed.

Rule of Law


Holding and Reasoning (Klingbiel, J.)

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