## Facts

- Robert Nicastro was injured in New Jersey when a metal-shearing machine severed four fingers on his right hand at his workplace.
- The machine was manufactured in England by J. McIntyre Machinery, Ltd., a British company.
- J. McIntyre sold its machines in the United States through an exclusive independent U.S. distributor.
- J. McIntyre personnel attended U.S. trade shows in several states to market the machines, but not in New Jersey.
- The record indicated no more than four J. McIntyre machines (possibly only one) reached New Jersey, including the machine involved in the injury.
- J. McIntyre did not advertise in New Jersey, send goods there directly, or otherwise direct conduct specifically toward New Jersey.

## Issues

1. Whether New Jersey courts could exercise specific personal jurisdiction, consistent with the Fourteenth Amendment Due Process Clause, over a foreign manufacturer whose product injured a forum resident when the manufacturer did not direct conduct at the forum state and the product entered the forum through a national distributor and limited sales.

## Decision

- The Supreme Court reversed the New Jersey Supreme Court and held New Jersey lacked personal jurisdiction over J. McIntyre.
- No majority opinion issued: a four-Justice plurality would require forum-state targeting; a two-Justice concurrence agreed jurisdiction was absent on narrower, fact-bound grounds; three Justices dissented.
- The plurality concluded J. McIntyre did not purposefully avail itself of New Jersey because it did not engage in conduct showing intent to invoke or benefit from New Jersey’s laws.
- The concurrence agreed that a single isolated sale (or very small number of sales) into the forum, without additional forum-directed conduct, was insufficient under existing precedent.
- The dissent would have found jurisdiction because J. McIntyre deliberately sought to serve the U.S. market through a distributor and trade-show marketing, and the injury occurred in New Jersey.

## Legal Principles

- Specific personal jurisdiction requires defendant conduct connecting it to the forum state such that the state’s exercise of power accords with due process.
- Purposeful availment generally requires actions by which the defendant invokes the benefits and protections of the forum state’s laws; contacts with the United States market in general do not necessarily establish contacts with a particular state.
- Placement of goods into a distribution channel, coupled only with foreseeability that the goods may reach the forum, is insufficient on the plurality’s approach; evidence of targeting the forum state is required.
- Under the concurrence’s narrower approach, isolated or minimal forum sales, without additional purposeful forum-directed conduct, do not establish specific jurisdiction; broader stream-of-commerce questions were left unresolved.

## Conclusion

The Court held that New Jersey could not exercise specific personal jurisdiction over a foreign manufacturer whose product caused injury in the state when the manufacturer did not direct conduct at New Jersey and the product arrived through a national distributor with only limited in-state sales, leaving competing doctrinal approaches without a single controlling rationale.


J. McIntyre Mach., Ltd. v. Nicastro, 564 U.S. 873 (2011)