This is a detailed analysis of the Ford Motor Co. v. Montana Eighth Judicial District Court Supreme Court decision from March 25, 2021. You can read the full opinion by clicking here.

This case involved two separate product liability lawsuits against Ford Motor Company, brought in Montana and Minnesota courts by residents injured in car accidents involving Ford vehicles. Ford challenged these courts’ personal jurisdiction, arguing that the courts lacked authority because the specific vehicles involved were neither designed, manufactured, nor originally sold in those states. Instead, they were sold out-of-state and only later ended up in Montana and Minnesota through resale or relocation.

Can a state court exercise specific personal jurisdiction over a corporation like Ford for claims arising from injuries caused by a product in that state, even if the product was not originally sold, designed, or manufactured in the forum state?

Supreme Court’s Holding:

The Court unanimously held that the Montana and Minnesota courts do have specific jurisdiction over Ford. The connection between Ford’s activities in the states and the plaintiffs' claims was strong enough to justify jurisdiction.

  1. Personal Jurisdiction Framework
    The Court reiterated the distinction between:

    • General jurisdiction: when a defendant is “essentially at home” in the forum (e.g., Ford’s incorporation in Delaware and headquarters in Michigan).
    • Specific jurisdiction: when the claim “arises out of or relates to” the defendant’s activities in the forum.

  2. Ford’s Activities in the Forum States
    Ford conceded it purposefully availed itself of the Montana and Minnesota markets through advertising, selling, maintaining dealerships, selling new and used vehicles, providing replacement parts, and fostering ongoing relationships with customers.

  3. Connection Between Ford’s Forum Activities and the Lawsuits
    Even though the particular vehicles involved in the accidents were not originally sold in Montana or Minnesota, Ford’s extensive efforts to serve these states’ markets meant the suits “relate to” its in-state activities.
    The Court rejected Ford’s argument that jurisdiction must be limited to the state where the car was first sold or manufactured, clarifying that “relate to” goes beyond strict causation.

  4. Precedent Cases

    • World-Wide Volkswagen Corp. v. Woodson was cited to support that when a company serves a market in a state and a product malfunctions there, jurisdiction is proper.
    • Bristol-Myers Squibb Co. v. Superior Court was distinguished because in Bristol-Myers the plaintiffs were not residents and had no in-state injury, unlike here.
    • Walden v. Fiore was distinguished because the defendant had no contacts with the forum state, unlike Ford.

  5. Fairness and Federalism Considerations
    The Court found it fair to hold Ford accountable in states where it systematically markets and supports its vehicles, especially since those states have a strong interest in protecting their residents.

Concurring Opinions:

  • Justice Alito agreed with the judgment but expressed concern about the Court’s new gloss on “arise out of or relate to” creating potential confusion by treating “relate to” as something separate from causation.
  • Justice Gorsuch (joined by Justice Thomas) questioned the continued viability of the current personal jurisdiction framework, noting that it may be outdated in the modern business environment and that the Court’s new “affiliation” test might complicate the doctrine further.

Practical Impact:

This ruling clarifies that states can exercise specific jurisdiction over companies that actively serve their markets when injuries occur there from products sold or used in those states—even if the specific product was not originally sold or made there. It broadens the understanding of how “relatedness” between a defendant’s forum contacts and the plaintiff’s claims can be satisfied.

For companies like Ford, it means they must expect to defend product liability suits in states where they have a substantial market presence and support network, not just where the particular product was first sold or manufactured.

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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