Brittany Day
In Ford Motor Co. v. Montana Eighth Judicial District Court, the Supreme Court will have the opportunity to redefine the nexus requirement for exercising personal jurisdiction over non-resident defendants. The Court will decide whether a national company with an extensive in-state market for a product is amenable to suit in a forum state under personal jurisdiction, even if the defendant’s contacts within that state were not the cause of injury. Since International Shoe Co. v. Washington, what “minimum contacts” are required to find jurisdiction has continuously evolved, especially because of the ever-growing national economy. Under one type of personal jurisdiction, specific jurisdiction, a plaintiff’s claims must “aris[e] out of or relate[] to the defendant’s contacts with the forum.” However, the Court has never had the opportunity to clarify the outer bounds of that phrase. Ford Motor Co. v. Montana Eighth Judicial District Court consolidated with Ford Motor Co. v. Bandemer, presents an opportunity for the Court to determine whether a finding of specific jurisdiction requires a causal connection between the defendant’s contacts and the plaintiff’s injury. The Court should adopt a broader relatedness test for specific jurisdiction, which would best align with previous Court precedent and the constitutional underpinnings of the jurisdictional analysis.
