## Facts

- Cassiar Mining Corporation, a Canadian company, mined and sold raw asbestos fibers, including sales into California.
- Ten California workers (or their survivors) sued Cassiar and others, alleging progressive lung disease from occupational asbestos exposure at California worksites.
- Plaintiffs alleged that some asbestos to which they were exposed in California originated from Cassiar’s mines and that Cassiar failed to provide adequate health warnings.
- Evidence showed Cassiar sold “thousands of tons” of raw asbestos fibers shipped directly to California locations over approximately 38 years.
- Cassiar argued plaintiffs could not, at the jurisdictional stage, directly trace the asbestos at their specific worksites to Cassiar’s California shipments.

## Issues

1. Whether California courts may exercise specific personal jurisdiction over a foreign asbestos supplier based on long-term, substantial shipments into California.
2. Whether the “arise out of or relate to” requirement for specific jurisdiction is satisfied when plaintiffs allege in-state exposure consistent with the defendant’s forum-directed sales, despite incomplete product identification at the jurisdiction stage.
3. Whether exercising jurisdiction over the foreign defendant is reasonable under due process.

## Decision

- The Court of Appeal denied Cassiar’s writ petition and left standing the trial court’s order denying the motion to quash service of summons.
- Cassiar’s decades of substantial, deliberate shipments of raw asbestos into California constituted purposeful direction toward the forum.
- Plaintiffs’ claims related sufficiently to Cassiar’s California-directed conduct because the alleged injuries stemmed from occupational asbestos exposure in California, the same market Cassiar systematically supplied.
- Due process did not require plaintiffs to conclusively trace their exposure to particular Cassiar shipments as a prerequisite to specific jurisdiction; that level of proof concerns the merits.
- Exercising jurisdiction was reasonable given California’s interest in adjudicating in-state occupational injury claims, plaintiffs’ interest in convenient relief, and Cassiar’s long-standing commercial exploitation of the California market.

## Legal Principles

- Specific jurisdiction requires (1) purposeful direction or availment, (2) claims that arise out of or relate to forum contacts, and (3) a reasonable exercise of jurisdiction consistent with fair play and substantial justice.
- Purposeful, substantial, and long-term direct shipments of a product into the forum support the purposeful-direction element.
- For the relatedness element, due process does not demand trial-level product identification at the jurisdictional stage; a substantial connection may exist where the forum contacts and the alleged in-forum injury involve the same type of product and conduct.
- The reasonableness inquiry weighs burden on the defendant, the forum state’s interests, and the plaintiff’s interest in effective relief; a defendant’s deliberate exploitation of the forum market reduces claims of unfairness.

## Conclusion

California courts could constitutionally exercise specific personal jurisdiction over Cassiar because it deliberately shipped large quantities of asbestos directly into California for decades and the workers’ claims for asbestos-related injuries from California exposure sufficiently related to that forum-directed conduct, making jurisdiction reasonable under due process.


Cassiar Mining Corp. v. Superior Court, 66 Cal. App. 4th 550 (Ct. App. 1998)