This is an analysis of the Ethridge v. Samsung case from the 5th Circuit in May 2025. You can read the full opinion by clicking here.

James Ethridge, a Texas resident, sued Samsung SDI, a South Korean battery manufacturer, after a Samsung 18650 lithium-ion battery exploded in his pocket in Texas, causing severe injuries. The key legal question was whether Texas courts had personal jurisdiction over Samsung, which does substantial business in Texas through sales to companies like Black & Decker, HP, and Dell, but does not sell directly to Texas consumers and has no physical presence in the U.S.

The district court dismissed Ethridge’s case, ruling Texas lacked personal jurisdiction over Samsung. Ethridge appealed.

Key Legal Issues:

  1. Personal Jurisdiction under Due Process:
    The court analyzed whether Texas could exercise specific personal jurisdiction consistent with the Fourteenth Amendment. Because Samsung is not “at home” in Texas (no principal place of business or incorporation), only specific jurisdiction applies. This requires: 

    • Samsung purposefully availed itself of the Texas market, 
    • Ethridge’s claim arises out of or relates to Samsung’s Texas contacts, and 
    • Exercising jurisdiction is fair and reasonable.

  2. Purposeful Availment:
    Samsung’s long-term contracts shipping 18650 batteries to Texas companies demonstrate purposeful availment. The court accepted that Samsung deliberately exploited the Texas market.

  3. Relatedness (Arising Out Of or Relating To):
    This was the crux. The Supreme Court’s recent decision in Ford Motor Co. v. Montana provided a “same product plus in-state injury” test: if the defendant sells a significant volume of the product in the forum state, and the plaintiff suffers injury in that state from the same product, that satisfies relatedness. Ethridge bought a Samsung 18650 battery (albeit from a Wyoming reseller), used it in Texas, and was injured in Texas.

    The majority applied this test to allow jurisdiction, rejecting Samsung’s argument that its sales to industrial customers (not direct consumers) in Texas break the connection. They ruled that limiting the market to only “business customers” is an unworkable and unsupported theory that conflicts with Supreme Court precedent.

  4. Fairness:
    Texas has a strong interest in protecting its residents injured in the state. Samsung can litigate there; thus, jurisdiction is fair.

Dissenting Opinion:
Judge Jones dissented, emphasizing that the defendant’s contacts must be connected to the plaintiff’s claims, not just a generalized market presence. Since Ethridge bought the battery through an unauthorized reseller, and Samsung deliberately avoided direct consumer sales in Texas, the dissent argued there was no purposeful availment for Ethridge’s claims. She stressed the importance of protecting defendants from being haled into courts where their forum contacts do not relate to the injury, citing Bristol-Myers and Walden as limiting principles.

Summary:
The majority reversed the dismissal, holding Texas courts have specific personal jurisdiction over Samsung because Samsung purposefully availed itself of the Texas market by selling the same type of battery to Texas businesses, and Ethridge’s injury arose from that product used in Texas. The dissent warned this could undermine due process protections by allowing jurisdiction based on indirect, unauthorized sales.

Girards Law Firm specializes in severe injury and wrongful death cases, especially those that involve brain damage, heart damage, spinal cord injuries or severe burns in Texas, Arkansas and Oklahoma. Contact us at www.girardslaw.com by using the chat feature for more information.

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