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Ford Motor Company v. Montana Eighth Judicial District Court

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Supreme Court of the United States
Ford Motor Company v. Montana Eighth Judicial District Court
Term: 2020-2021
(Originally 2019-2020)
Important Dates
Argument: October 7, 2020
(Postponed from April 27, 2020)
Decided: March 25, 2021
Outcome
Affirmed
Vote
8-0
Majority
Elena Kagan • Chief Justice John G. Roberts • Stephen Breyer • Sonia Sotomayor • Brett Kavanaugh
Concurring
Samuel Alito • Neil Gorsuch • Clarence Thomas


Ford Motor Company v. Montana Eighth Judicial District Court is a case argued before the Supreme Court of the United States on October 7, 2020, during the court's October 2020-2021 term. The case came on a writ of certiorari to the Montana Supreme Court.[1] It was consolidated with Ford Motor Company v. Bandemer.[2][3]

In a unanimous ruling, the court affirmed the Montana and Minnesota Supreme Courts' decisions, holding that Ford's contacts and activities within the states were sufficient to give Montana's and Minnesota's courts specific jurisdiction over Ford. Justice Elena Kagan delivered the majority opinion of the court. Justices Samuel Alito and Neil Gorsuch filed concurring opinions. Justice Amy Coney Barrett took no part in the consideration or decision of the case.[4]

Oral argument for Ford Motor Company v. Montana Eighth Judicial District Court was initially scheduled for April 27, 2020, during the court's October 2019-2020 term. However, the U.S. Supreme Court announced on April 3 that it was postponing the eight oral arguments originally scheduled during its April sitting. In a press release, the court said the delay was "in keeping with public health guidance in response to COVID-19."[5] COVID-19 is the abbreviation for coronavirus disease 2019, caused by SARS-CoV-2.

HIGHLIGHTS
  • The case: In both cases, Ford vehicles were driven in car accidents. In one case based in Minnesota, a passenger sustained a severe brain injury and filed a claim against Ford Motor Company for vehicle defect alleging that the passenger-side airbag failed to deploy. In the second case based in Montana, one of the vehicle tires experienced a tread/belt separation, the car lost stability and rolled into a ditch, and the driver perished at the scene. A personal representative filed claims against Ford for liability and negligence. Ford Motor Company moved to dismiss both claims in state district court, citing a lack of personal jurisdiction. In both cases, Ford's motions were denied. On appeal in both cases, the state courts of appeal affirmed the rulings of the district courts. Ford appealed the cases to the state supreme courts which affirmed the rulings of the courts of appeal. Click here for more details about Ford Motor Company v. Montana Eighth Judicial District Court and here for more information about Ford Motor Company v. Bandemer.
  • The issue: Whether the “arise out of or relate to” requirement of the Fourteenth Amendment's due process clause permits a state court to exercise specific personal jurisdiction over a nonresident defendant under Burger King Corp. v. Rudzewicz when none of the defendant’s forum contacts caused the plaintiff’s claims, such that the plaintiff’s claims would be the same even if the defendant had no forum contacts.[1][6]
  • The outcome: In a unanimous ruling, the court affirmed the Montana and Minnesota Supreme Courts' decisions, holding that Ford's contacts and activities within the states were sufficient to give Montana's and Minnesota's courts specific jurisdiction over Ford.[4]


    • You can review the lower court's opinion here for the Montana Supreme Court and here for the Minnesota Supreme Court.[7][8]

    Timeline

    The following timeline details key events in Ford Motor Company v. Montana Eighth Judicial District Court:

    • March 25, 2021: The U.S. Supreme Court affirmed the rulings of the Montana Supreme Court and Minnesota Supreme Court.
    • October 7, 2020: Oral argument was heard.
    • April 3, 2020: The U.S. Supreme Court postponed its April sitting. Oral arguments in Ford Motor Company v. Montana Eighth Judicial District Court were initially scheduled for April 27, 2020.
    • January 17, 2020: The U.S. Supreme Court agreed to hear the case.
    • September 18, 2019: Ford Motor Company filed a petition with the U.S. Supreme Court.
    • May 21, 2019: The Montana Supreme Court granted Ford Motor Company's writ of supervisory control and affirmed the ruling of the Eighth District.

    The following timeline details key events in Ford Motor Company v. Bandemer:

    • January 17, 2020: The U.S. Supreme Court agreed to hear the case.
    • September 18, 2019: Ford Motor Company filed a petition with the U.S. Supreme Court.
    • July 31, 2019: The Minnesota Supreme Court affirmed the ruling of the Minnesota Court of Appeals.

    Background

    Ford Motor Company v. Montana Eighth Judicial District Court

    In 2015, Montana resident Markkaya Jean Gullett drove a 1996 Ford Explorer. The vehicle was assembled in Kentucky and originally sold in Washington. While driving on the Montana interstate, one of the vehicle tires experienced a tread/belt separation. The vehicle lost stability and rolled into a ditch, landing upside down. Gullett perished at the scene of the accident. Gullett's personal representative, Charles Lucero, filed suit against Ford Motor Company in Montana district court on behalf of Gullett and her heirs. Lucero alleged three claims against Ford: negligence, strict liability for design defect, and strict liability for failure to warn.[7]

    Ford Motor Company moved to dismiss the claims, citing a lack of personal jurisdiction. Ford argued that there was no link between Ford's Montana contacts and Lucero's claims. On October 10, 2018, the district court denied Ford's motion to dismiss, holding that specific personal jurisdiction over Ford did exist. Ford appealed the decision to the Montana Supreme Court, asking the court to exercise supervisory control over the district court, find no specific personal jurisdiction exists, and dismiss the case against Ford.[7]

    On May 21, 2019, the Montana Supreme Court granted Ford's petition for supervisory control over the district court, and affirmed the district court's ruling denying Ford's motion to dismiss for lack of personal jurisdiction.[7]

    Ford Motor Company v. Bandemer

    In January 2015, Minnesota resident Adam Bandemer was a passenger in a 1994 Ford Crown Victoria driven on a Minnesota road by defendant and Minnesota resident Eric Hanson. Hanson rear-ended a Minnesota county snowplow and his car ended up in a ditch. Bandemer sustained a severe brain injury during the accident; he alleged that the accident was caused by Hanson's negligence and that the passenger-side airbag did not deploy during the accident as a result of a vehicle defect. He filed a complaint in district court alleging products liability, negligence, and breach of warranty claims against Ford Motor Company, and negligence claims against Eric Hanson and Hanson's father, who was the owner of the vehicle.[8]

    Ford Motor Company moved to dismiss Bandemer's claims citing a lack of personal jurisdiction. Ford argued that because the 1994 Crown Victoria was not designed, manufactured, or originally sold in Minnesota, Ford could not be subject to personal jurisdiction in Minnesota on the claim. In May 2017, the district court held that the exercise of jurisdiction over Ford Motor Company was proper. Ford appealed the decision to the Minnesota Court of Appeals.[8]

    On April 23, 2018, the Minnesota Court of Appeals affirmed the ruling of the district court. The appellate court held that Ford's marketing contacts with Minnesota established a substantial connection among the parties in the case and the forum of the State of Minnesota, and that the contacts were satisfactorily related to the cause of the action.[8]

    On July 31, 2019, the Minnesota Supreme Court affirmed the Minnesota Court of Appeals' decision.[8]


    Questions presented

    The petitioner presented the following questions to the court:

    Questions presented:
    • Whether the “arise out of or relate to” requirement of the Fourteenth Amendment's due process clause permits a state court to exercise specific personal jurisdiction over a nonresident defendant under Burger King Corp. v. Rudzewicz when none of the defendant’s forum contacts caused the plaintiff’s claims, such that the plaintiff’s claims would be the same even if the defendant had no forum contacts.[1][6]

    Outcome

    In a unanimous ruling, the court affirmed the Montana and Minnesota Supreme Courts' decisions, holding that Ford's contacts and activities within the states were sufficient to give Montana's and Minnesota's courts specific jurisdiction over Ford. Justice Elena Kagan delivered the majority opinion of the court. Justices Samuel Alito and Neil Gorsuch filed concurring opinions. Justice Amy Coney Barrett took no part in the consideration or decision of the case.[4]

    Opinion

    In her opinion, Justice Elena Kagan wrote:[4]

    “ In each of these two cases, a state court held that it had jurisdiction over Ford Motor Company in a products liability suit stemming from a car accident. The accident happened in the State where suit was brought. The victim was one of the State’s residents. And Ford did substantial business in the State—among other things, advertising, selling, and servicing the model of vehicle the suit claims is defective. Still, Ford contends that jurisdiction is improper because the particular car involved in the crash was not first sold in the forum State, nor was it designed or manufactured there. We reject that argument. When a company like Ford serves a market for a product in a State and that product causes injury in the State to one of its residents, the State’s courts may entertain the resulting suit.


    Ford is a global auto company. It is incorporated in Delaware and headquartered in Michigan. But its business is everywhere. Ford markets, sells, and services its products across the United States and overseas. In this country alone, the company annually distributes over 2.5 million new cars, trucks, and SUVs to over 3,200 licensed dealerships.

    ... Accidents involving two of Ford’s vehicles—a 1996 Explorer and a 1994 Crown Victoria—are at the heart of the suits before us.

    ... Ford moved to dismiss the two suits for lack of personal jurisdiction, on basically identical grounds. According to Ford, the state court (whether in Montana or Minnesota) had jurisdiction only if the company’s conduct in the State had given rise to the plaintiff ’s claims. And that causal link existed, Ford continued, only if the company had designed, manufactured, or—most likely—sold in the State the particular vehicle involved in the accident. In neither suit could the plaintiff make that showing.

    ... Both the Montana and the Minnesota Supreme Courts (affirming lower court decisions) rejected Ford’s argument.

    ...The Fourteenth Amendment’s Due Process Clause limits a state court’s power to exercise jurisdiction over a defendant. The canonical decision in this area remains International Shoe Co. v. Washington, 326 U. S. 310 (1945). There, the Court held that a tribunal’s authority depends on the defendant’s having such “contacts” with the forum State that “the maintenance of the suit” is “reasonable, in the context of our federal system of government,” and “does not offend traditional notions of fair play and substantial justice.” Id., at 316–317 (internal quotation marks omitted). In giving content to that formulation, the Court has long focused on the nature and extent of “the defendant’s relationship to the forum State.” Bristol-Myers Squibb Co. v. Superior Court of Cal., San Francisco Cty., 582 U. S. ___, ___ (2017) (slip op., at 5) (citing cases). That focus led to our recognizing two kinds of personal jurisdiction: general (sometimes called all-purpose) jurisdiction and specific (sometimes called case-linked) jurisdiction. See Goodyear Dunlop Tires Operations, S. A. v. Brown, 564 U. S. 915, 919 (2011).

    ... Specific jurisdiction is different: It covers defendants less intimately connected with a State, but only as to a narrower class of claims. The contacts needed for this kind of jurisdiction often go by the name “purposeful availment.” Burger King Corp. v. Rudzewicz, 471 U. S. 462, 475 (1985).

    ... And indeed, this Court has stated that specific jurisdiction attaches in cases identical to the ones here—when a company like Ford serves a market for a product in the forum State and the product malfunctions there.

    ... Here, resident-plaintiffs allege that they suffered in-state injury because of defective products that Ford extensively promoted, sold, and serviced in Montana and Minnesota. For all the reasons we have given, the connection between the plaintiffs’ claims and Ford’s activities in those States—or otherwise said, the “relationship among the defendant, the forum[s], and the litigation”—is close enough to support specific jurisdiction. Walden, 571 U. S., at 284 (internal quotation marks omitted).

    The judgments of the Montana and Minnesota Supreme Courts are therefore affirmed.[9]

    		”
    —Justice Elena Kagan

    Concurring opinion

    Justice Alito's concurring opinion

    Justice Samuel Alito filed a concurring opinion.[4]

    In his concurrence, Justice Alito wrote:[4]

    “ Ford ... asks us to adopt an unprecedented rule under which a defendant’s contacts with the forum State must be proven to have been a but-for cause of the tort plaintiff ’s injury. The Court properly rejects that argument, and I agree with the main thrust of the Court’s opinion. My only quibble is with the new gloss that the Court puts on our case law. Several of our opinions have said that a plaintiff ’s claims “‘must arise out of or relate to the defendant’s contacts’ ” with the forum. See ante, at 6 (citing cases). The Court parses this phrase “as though we were dealing with language of a statute,” Reiter v. Sonotone Corp., 442 U. S. 330, 341 (1979), and because this phrase is cast in the disjunctive, the Court recognizes a new category of cases in which personal jurisdiction is permitted: those in which the claims do not “arise out of ” (i.e., are not caused by) the defendant’s contacts but nevertheless sufficiently “relate to” those contacts in some undefined way, ante, at 8–9.


    This innovation is unnecessary and, in my view, unwise. To say that the Constitution does not require the kind of proof of causation that Ford would demand—what the majority describes as a “strict causal relationship,” ante, at 8— is not to say that no causal link of any kind is needed. And here, there is a sufficient link.

    I would leave the law exactly where it stood before we took these cases, and for that reason, I concur in the judgment.[9]

    		”
    —Justice Samuel Alito

    Justice Gorsuch's concurring opinion

    Justice Neil Gorsuch also filed a concurring opinion, which Justice Clarence Thomas joined.[4] In his concurrence, Justice Gorsuch wrote:[4]

    “ Since International Shoe Co. v. Washington, 326 U. S. 310 (1945), this Court’s cases have sought to divide the world of personal jurisdiction in two. A tribunal with “general jurisdiction” may entertain any claim against the defendant.

    ... Meanwhile, “specific jurisdiction” affords a narrower authority. It applies only when the defendant “‘purposefully avails’” itself of the opportunity to do business in the forum State and the suit “‘arise[s] out of or relate[s] to’” the defendant’s contacts with the forum State. Burger King Corp. v. Rudzewicz, 471 U. S. 462, 472, 475 (1985).

    While our cases have long admonished lower courts to keep these concepts distinct, some of the old guardrails have begun to look a little battered.

    ... Today’s case tests the old boundaries from another direction. Until now, many lower courts have proceeded on the premise that specific jurisdiction requires two things. First, the defendant must “purposefully avail” itself of the chance to do business in a State. Second, the plaintiff ’s suit must “arise out of or relate to” the defendant’s in-state activities. Typically, courts have read this second phrase as a unit requiring at least a but-for causal link between the defendant’s local activities and the plaintiff ’s injuries. E.g., Tamburo v. Dworkin, 601 F. 3d 693, 708–709 (CA7 2010) (collecting cases); see also Burger King, 471 U. S., at 475 (discussing “proximate[] results”).

    ... Now, though, the Court pivots away from this understanding.

    ...In particular, the majority zeros in on the disjunctive conjunction “or,” and proceeds to build its entire opinion around that linguistic feature. Ante, at 8–9. The majority admits that “arise out of ” may connote causation. But, it argues, “relate to” is an independent clause that does not.

    Where this leaves us is far from clear. For a case to “relate to” the defendant’s forum contacts, the majority says, it is enough if an “affiliation” or “relationship” or “connection” exists between them. Ante, at 6, 12, 16. But what does this assortment of nouns mean? Loosed from any causation standard, we are left to guess. The majority promises that its new test “does not mean anything goes,” but that hardly tells us what does. Ante, at 9.

    ... The real struggle here isn’t with settling on the right outcome in these cases, but with making sense of our personal jurisdiction jurisprudence and International Shoe’s increasingly doubtful dichotomy. On those scores, I readily admit that I finish these cases with even more questions than I had at the start. Hopefully, future litigants and lower courts will help us face these tangles and sort out a responsible way to address the challenges posed by our changing economy in light of the Constitution’s text and the lessons of history.[9]

    		”
    —Justice Neil Gorsuch

    Text of the opinion

    Oral argument

    Audio

    Audio of oral argument:[10]



    Transcript

    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 SCOTUSblog, "Ford Motor Company v. Montana Eighth Judicial District Court," accessed January 17, 2020
    2. ↑ Ford Motor Company v. Bandemer came on a writ of certiorari to the Minnesota Supreme Court. The docket number is 19-369.
    3. ↑ SCOTUSblog, "Ford Motor Company v. Bandemer," accessed January 20, 2020
    4. ↑ 4.0 4.1 4.2 4.3 4.4 4.5 4.6 4.7 Supreme Court of the United States, Ford Motor Company v. Montana Eighth Judicial District Court, decided March 25, 2021
    5. ↑ U.S. Supreme Court, "Press release from April 3, 2020," accessed April 3, 2020
    6. ↑ 6.0 6.1 SCOTUSblog, "Ford Motor Company v. Bandemer," accessed January 20, 2020
    7. ↑ 7.0 7.1 7.2 7.3 Supreme Court of the State of Montana, "Ford Motor Co. v. Mont. Eighth Judicial Dist. Court," decided May 21, 2019
    8. ↑ 8.0 8.1 8.2 8.3 8.4 Supreme Court of the State of Minnesota, "Adam Bandemer v. Ford Motor Company," decided July 31, 2019
    9. ↑ 9.0 9.1 9.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    10. ↑ Supreme Court of the United States, "Oral Argument - Audio," accessed October 12, 2020
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