Civ Pro Jurisdiction Cases

Goodyear – is there general jurisdiction for tires sold in NC?

bus tire accident in France; out of state Ds only subject to general jurisdiction where “essentially at home”, products entering through stream of commerce is NOT general jurisdiction – that is specific

Daimler - is there general jurisdiction for subsidiary’s extensive contacts in California?

Argentinian Ps sued Daimler in CA based on it’s subsidiary’s big CA presence; home refers to a small number of places in which a corp’s contacts are strongest relative to everywhere else; no reasonableness prong in general jurisdiction

BNSF – is there general jurisdiction for company’s extensive railroad operations in montana?

Nationwide RR incorp in DE, PPB in TX, sued in Montana where does some business; doing a lot of business in the forum is not enough for an exceptional circumstance establishing general jurisdiction

Pennoyer v Neff - Presence of property and person as the foundation for PJ

OR court issued a default judgement after service by publication on a nonresident for personal debt; PJ is linked with due process – D needs fair notice and chance to defend, court must act within territorial powers

Harris v Balk

MD creditor attached an NC debtor’s claim because the NC debtor traveled to MD; debts “followed the debtor” allowing quasi in rem jurisdiction – overruled by Shaffer

Hess v Pawloski

if you drive a car in a state, you are impliedly consenting to be sued there for accidents – “fiction of implied consent” = no longer valid on its own under Int Shoe

International Shoe

WA sought to collect taxes from Shoe in WA whos salesman operated there, incorp in DE, PPB MO; replaced “presence” with minimum contacts, sliding scale of contacts vs relatedness

McGee v International Life Ins Co – TX insurance company insures person in CA

CA beneficiary sued out of state insurer based on a single insurance contract; one strong, related contact can establish specific jurisdiction when the claim arises directly from that contact

Hanson v Denckla DE trust company has trustee in FL

FL P tried to assert jurisdiction over a DE trustee whose only connection was that the settlor moved to FL; unilateral actions of Ps cannot create jurisdiction, need purposeful availment – action by D which he purposefully avails himself to privilege of conducting activities in forum state

Shaffer v Heitner - Delaware law makes those board directors with shares in a Delaware corporation subject to personal jurisdiction

DE tried to assert quasi in rem jurisdiction by seizing stock of corp directors for acts occurring elsewhere; International Shoe applies to all forms of jurisdiction, property presence alone is insufficient (satisfy minimum contacts regardless)

Helicopteros - Colombian helicopter company has contacts with Texas

Helicol had training, purchases, and negotiations in TX but accident occurred in Peru; established difference between specific and general jurisdiction, Purchases and training trips aren’t enough for general jurisdiction; plaintiffs conceded specific jurisdiction, so none existed

World Wide Volkswagen – New Yorkers drive to Oklahoma

NY car dealer sued in OK after crash caused by a car sold in NY that got in accident in OK; Pure stream of commerce – purposeful availment when D has expectation that product will end up in state, but broken by unilateral activity of purchasers; mere foreseeability not enough, must reasonably anticipate being hauled into court there

Asahi – Japanese tire valve manufacturer has valves that end up in California

no jurisdiction, but 3 theories – pure stream of commerce (Brennan), pure stream of commerce + (O’Connor), stream of commerce + and quantity/quality (Stevens)

J McIntyre v Nicastro

UK manufacturer sold machines through national distributor, one reaches NJ and causes injury; Plurality requires purposeful targeting of the particular state, not just the U.S. market, no jurisdiction

Calder v Jones – Story about Hollywood star’s alleged alcohol addiction gets published in California

Effects test, jurisdiction exists where defendants aim intentional acts at the forum knowing harm will be felt there

Walden v Fiore – Nevada gamblers have money seized and false affidavit written in Georgia

Contacts must be with the forum state, not just the plaintiff; knowing harm will be felt in the forum is insufficient

Bristol Meyers – Can out-of-state consumers of prescription drug file suit in California along with California consumers?

State courts require a direct connection between forum and each plaintiff’s claim, mass forum shopping is restricted

Ford Motor Co – Does an accident involving a car purchased in one state lead to jurisdiction for an accident in the state where the accident occurred?

Injuries in MN and MT from cars not originally sold or manufactured there; D is subject to suit in a state where it has minimum contacts showing availment + arises out of or relates to contacts; “Relates to” = some meaningful connection or relationship among Defendant, Forum, and Litigation (broader than causation)

Mas v Perry

Married grad students sued landlord, issue was wife’s domicile; Domicile = residence + intent to remain indefinitely; marriage to an alien doesn’t change domicile.

Grupo Dataflux – Non-diverse partner leaves the partnership

Diversity is determined at filing; jurisdiction can’t be cured by a partner changing citizenship, only by dropping a nondiverse party

Caterpillar v Lewis

Court held jurisdiction was proper at time of judgment because defect cured by party removal

Louisville & Nashville RR v Mottley – Plaintiffs sue for breach of contract because they lose their lifetime railroad passes

well pleaded complaint rule - Federal question must appear on the face of plaintiff’s complaint; cannot rely on defenses or anticipated issues

Smith v KC Tile

State law claim depended on constitutionality of federal bond program; Federal question exists when plaintiff’s right to relief necessarily turns on federal law.

Moore v Chesapeake & Ohio Ry

Worker used state tort claim referencing federal safety statute; Reference to federal law isn’t enough, claim itself must arise under federal law.

Merrel Dow v Thompson – State makes violations of FDA a cause of action

No federal jurisdiction when federal statute lacks a private cause of action (arising under) and is not substantial to the federal system; federal ingredient alone is not arising under

Grable & Sons v Darue – Quiet title claim involves issue of tax law

state law claims can “arise under” when they raise a necessarily disputed, substantial federal issue suitable for federal court

Gunn v Minton – Malpractice suit after patent suit

Federal issue was not substantial to the federal system as a whole, and state court adjudication does not upset state/fed balance

Allapattah – some plaintiffs don’t meet the amount-in-controversy requirement

If one diverse plaintiff meets AIC and complete diversity exists, others can piggyback via supplemental jurisdiction; complete diversity cannot be supplemented

Swift v Tyson – 1842 case interpreting Rules of Decision Act

Federal courts applied general federal common law in diversity. Overruled by Erie.

Erie RR – 1938 case interpreting Rules of Decision Act

Federal courts must apply state substantive law and federal procedural law; twin aims = avoid forum shopping and inequitable administration

Guaranty Trust v York

must fed courts apply state SOLs?; Outcome-determinative test - if ignoring state law would change the result, state law applies

Ragan v Merchants Transfer

Filing v service for SOL tolling; state tolling rules apply, FRCP not directly on point

Byrd v Blue Ridge – does state law that judge decides whether person is a statutory employee control in federal court?

Even if outcome-determinative, strong federal interests (jury system) can outweigh state procedures

Hanna v Plumer – does state law that executor of estate must be personally served control in federal court?

If an FRCP is directly on point and valid under REA, it governs, no Erie analysis needed

Walker v Armco Steel – does state law that statute of limitations is tolled upon service control in federal court?

When no direct conflict with FRCP, apply state law