## Facts

- Two products-liability suits were filed in state court: one in Montana for a fatal rollover involving a 1996 Ford Explorer, and one in Minnesota for injuries involving a 1994 Ford Crown Victoria with alleged airbag failure.
- The plaintiffs were residents of the forum states, and the accidents occurred in those states.
- The vehicles were designed and manufactured outside Montana and Minnesota and were originally sold outside those states; they entered the forum states through later resales and relocations by consumers.
- Ford Motor Company is incorporated in Delaware and headquartered in Michigan.
- Ford conducted substantial, continuous business in Montana and Minnesota, including advertising, selling, and servicing the same vehicle models alleged to be defective, and selling replacement parts and providing repair services in those states.
- Ford moved to dismiss both actions for lack of personal jurisdiction, arguing due process required that its in-state conduct cause the plaintiffs’ claims by involving the specific vehicles at issue.
- The Montana and Minnesota Supreme Courts held their courts had specific personal jurisdiction over Ford; Ford sought and obtained Supreme Court review in consolidated cases.

## Issues

1. Whether the Due Process Clause permits Montana and Minnesota courts to exercise specific personal jurisdiction over Ford in products-liability suits arising from in-state accidents when the particular vehicles were not designed, manufactured, or first sold in the forum states.
2. Whether the requirement that a claim “arise out of or relate to” a defendant’s forum contacts demands a strict causal link between those contacts and the specific product that injured the plaintiff.

## Decision

- The Supreme Court affirmed (8–0; Justice Barrett did not participate).
- The Court held that the connection between the plaintiffs’ claims and Ford’s forum-state activities was sufficient for specific personal jurisdiction.
- The Court rejected Ford’s proposed rule that jurisdiction requires Ford to have designed, manufactured, or first sold the particular vehicles in the forum states.
- The Court concluded the suits “relate to” Ford’s extensive in-state conduct because Ford systematically served a market in Montana and Minnesota for the same models involved in the accidents, and the injuries occurred there to forum residents.
- Justice Alito concurred in the judgment, emphasizing that the result could be justified without expanding the “relate to” concept.
- Justice Gorsuch, joined by Justice Thomas, concurred in the judgment and questioned the coherence of existing personal-jurisdiction doctrine while agreeing jurisdiction was proper here.

## Legal Principles

- General jurisdiction over a corporation typically exists only where it is “essentially at home” (usually its place of incorporation and principal place of business); absent that, jurisdiction must be specific.
- Specific jurisdiction requires that the plaintiff’s claims “arise out of or relate to” the defendant’s contacts with the forum.
- The “relate to” component has independent force and can support specific jurisdiction without a strict causal showing tying the defendant’s forum contacts to the specific item that caused injury.
- A state may exercise specific jurisdiction when a defendant deliberately and systematically serves a forum market for the product line at issue and an in-state injury to a forum resident is meaningfully connected to those forum-directed activities.
- Due process limits remain: jurisdiction is not proper based on isolated or sporadic contacts; the defendant’s forum conduct must be substantial and connected to the type of claim asserted.

## Conclusion

The Court held that Montana and Minnesota could exercise specific personal jurisdiction over Ford because Ford extensively cultivated markets in those states for the same vehicle models involved in in-state accidents, making the residents’ products-liability claims sufficiently related to Ford’s forum contacts even though the particular vehicles were first sold elsewhere.


Ford Motor Co. v. Mont. Eighth Jud. Dist. Ct., 592 U.S. 351 (2021)