Facts
- Hundreds of plaintiffs filed coordinated product-liability suits in California state court alleging injuries from the prescription drug Plavix, asserting theories including design defect, failure to warn, and misrepresentation.
- The plaintiff group included California residents and many nonresidents from numerous other states.
- Bristol-Myers Squibb Co. (BMS) was incorporated in Delaware and headquartered in New York; it had substantial operations and a sales presence in California and sold Plavix in California.
- BMS also used a California-based distributor to distribute Plavix nationally.
- For the nonresident plaintiffs, the relevant events did not occur in California: they did not obtain, ingest, or suffer injury from Plavix in California, and they were not treated in California.
- Plavix was not designed, developed, manufactured, labeled, packaged, or approved in California.
- BMS conceded personal jurisdiction in California for claims by California-resident plaintiffs but moved to quash service as to nonresident plaintiffs for lack of personal jurisdiction.
- California courts rejected general jurisdiction after modern Supreme Court doctrine, but the California Supreme Court upheld specific jurisdiction using a “sliding scale” that relaxed the claim-to-forum connection based on BMS’s extensive California contacts.
Issues
- Whether due process permits California courts to exercise specific personal jurisdiction over BMS for nonresident plaintiffs’ Plavix claims when the nonresidents’ alleged injuries and relevant conduct occurred outside California.
- Whether extensive but claim-unrelated contacts with the forum, combined with similarity to resident plaintiffs’ claims, can satisfy the “arise out of or relate to” requirement for specific jurisdiction.
Decision
- The Supreme Court reversed and remanded.
- California lacked general jurisdiction over BMS because BMS was not “at home” in California.
- California also lacked specific jurisdiction over the nonresident plaintiffs’ claims because those claims did not “arise out of or relate to” BMS’s California contacts.
- The Court rejected California’s “sliding scale” approach as inconsistent with due process because it functioned like an improper form of general jurisdiction.
- Similarity between resident and nonresident claims involving the same product did not establish a sufficient connection between California and the nonresidents’ claims.
- BMS’s California activities unrelated to Plavix, and its contract with a California distributor for nationwide distribution, did not provide the required claim-specific forum link.
- The Court noted that nonresident plaintiffs could sue in states tied to their prescriptions, purchases, ingestion, or injuries, or where BMS was “at home,” and it did not decide how different federal service rules might affect a federal-court mass action.
Legal Principles
- Specific jurisdiction requires an affiliation between the forum and the underlying controversy, typically an in-state activity or occurrence that is subject to the forum state’s regulation.
- A defendant’s forum contacts must connect to the particular claims asserted; extensive in-state contacts do not permit adjudication of claims lacking a forum nexus.
- Courts may not dilute the “arise out of or relate to” requirement based on the quantity of a defendant’s general forum activity.
- Federalism limits a state’s adjudicatory authority over disputes centered in other states, independent of convenience or efficiency considerations.
Conclusion
The Court held that due process forbids a state court from exercising specific personal jurisdiction over a corporate defendant for nonresident plaintiffs’ claims when the claims lack a claim-specific connection to the defendant’s forum conduct, even if the defendant has substantial in-state operations and resident plaintiffs assert similar claims about the same product.