Ford Motor Co. v. Montana Eighth Judicial District Court

Case brief summary

Facts

Ford cars crashed in Montana and Minnesota, hurting local residents. Those specific cars were made and first sold elsewhere, but Ford heavily advertised, sold, and serviced that car model in both states.

Procedural history

Injured people sued Ford in Montana and Minnesota courts. Ford claimed those courts had no power over it since the cars weren't made or sold there. State courts disagreed, so Ford appealed to the Supreme Court.

Issue

Can a state court hear a lawsuit against a company whose product hurt someone there, even if that specific product wasn't made or sold there, as long as the company actively sells that product in the state?

Holding

Yes. When a company works to sell and support a product in a state, and that kind of product hurts one of the state's residents there, the state's courts can hear the case.

Reasoning

The Court said the rule has always been that a lawsuit must either be caused by or related to the company's activities in the state, not only strictly caused by them. Ford deliberately advertised, sold, and serviced these car models in Montana and Minnesota for years, so there was a strong connection between Ford's in-state business and the accidents that happened there. This also fit with fairness to Ford, since it benefits from doing business in these states, and with respecting each state's interest in protecting its own residents.

Opinions

Majority (Kagan): Jurisdiction is proper because Ford's extensive in-state marketing and sales of these car models relate closely enough to the in-state crashes.

Concurrences (Alito, Gorsuch joined by Thomas): Alito agrees with the outcome but thinks the old causation-based test already works and the new relate-to standard is unnecessary and vague. Gorsuch, joined by Thomas, agrees with the result but argues the entire framework for deciding when courts have power over companies needs rethinking.