J. McIntyre Machinery, Ltd. v. Nicastro
The Supreme Court ruled that New Jersey courts could not hear a factory worker's lawsuit against a British machine manufacturer, because the company never specifically tried to sell its products in New Jersey — it only sold nationwide through an independent distributor.
No single opinion commanded a majority, but six justices agreed the lawsuit could not proceed in New Jersey, leaving companies and injured consumers with continued uncertainty about when foreign manufacturers can be sued in a particular state.
“Due process protects the defendant’s right not to be coerced except by lawful judicial power.”
The plurality's core premise that jurisdiction rests on lawful authority, not mere fairness.
How it got here: A New Jersey trial court and the New Jersey Supreme Court both allowed the suit to proceed; the manufacturer asked the Supreme Court to review that ruling.
The Case in Depth
What happened
Robert Nicastro lost fingers on his hand while using a metal-shearing machine at his New Jersey workplace. The machine was made in England by J. McIntyre Machinery, which sold its products in the United States through an independent distributor rather than directly. Nicastro sued the manufacturer in New Jersey state court, but the company argued New Jersey courts had no power over it since it never specifically targeted that state.
The question before the Court
Could a New Jersey court hear an injury lawsuit against a British machine maker whose products reached the state only through an independent U.S. distributor?
The Court's answer
No — a plurality of the Court, joined in the outcome by two more justices, ruled that New Jersey could not exercise jurisdiction over the British manufacturer. The company had not purposefully directed any activity at New Jersey specifically; it merely sold products nationwide through an independent distributor, and a handful of machines happened to end up in the state. That kind of indirect, unintentional connection is not enough to satisfy due process.
The justices could not agree on a single reason why. Four justices, led by Justice Kennedy, said jurisdiction requires proof the company intended to submit to a particular state's authority. Two more justices, in a separate opinion by Justice Breyer, reached the same result more cautiously, relying on existing precedent without adopting a broad new rule. Three dissenting justices would have allowed the suit, arguing the company's deliberate effort to sell nationwide made New Jersey a fair place to sue.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
People injured by foreign-made products may have a harder time suing in the state where they were hurt if the manufacturer sold through a national distributor rather than targeting that state directly. Foreign manufacturers gain some protection from being sued in any state where their products merely happen to end up.
What changes now
The New Jersey Supreme Court's ruling is undone, so Nicastro's lawsuit cannot proceed in New Jersey courts as filed; he could potentially pursue relief elsewhere, such as suing the distributor or seeking a different forum. Because no opinion commanded five votes for a single legal standard, lower courts remain without a unified nationwide test for when foreign manufacturers using national distributors can be sued in a particular state.
What this does not decide
The decision does not establish one binding legal test, since no opinion won five votes for a single rationale. It leaves open how courts should handle jurisdiction over sellers using internet sales, online marketplaces, or other modern distribution methods not present in this case.
Concurrences and dissents
Concurrence — Justice Breyer
Justice Breyer agreed the New Jersey judgment must be reversed but refused to join the plurality's broader reasoning about purposeful availment and sovereign authority. He argued the case could be resolved simply by applying existing precedents, which require more than a single isolated sale and general marketing efforts to establish jurisdiction, and warned against announcing sweeping new rules without considering how they would apply to modern commerce like internet sales.
Dissent — Justice Ginsburg
“But instead, six Justices of this Court, in divergent opinions, tell us that the manufacturer has avoided the jurisdiction of our state courts, except perhaps in States where its products are sold in sizeable quantities.”Ginsburg's objection that the splintered Court let the manufacturer escape accountability.
Justice Ginsburg argued that the manufacturer had deliberately built a nationwide U.S. sales network through its distributor, intending to profit from sales anywhere in the country, including New Jersey. She contended it was fundamentally fair to let an injured worker sue where the injury actually occurred, and criticized the plurality for reviving a discredited 'consent' based theory of jurisdiction that a majority of the Court did not actually endorse.
How the Court got there
The legal reasoning, step by step
- The plurality explained that a court can only force a defendant to face a lawsuit if that defendant purposefully availed itself of a state's market — meaning it deliberately reached out to do business there, not merely that its products happened to arrive there.
- The plurality rejected New Jersey's 'stream-of-commerce' theory, under which a manufacturer could be sued anywhere a national distribution network might carry its goods, reasoning that merely predicting where goods might end up is not the same as targeting a specific state.
- Applying that standard, the plurality found the manufacturer's only connection to New Jersey was that a distributor sold a handful of machines there; the company had no office, employees, advertising, or property in the state, so it had not purposefully directed activity at New Jersey.
- Justice Breyer's separate opinion, providing the fifth and sixth votes for reversing, avoided announcing any broad new rule and instead applied existing precedent narrowly, concluding that a single isolated sale and general trade-show attendance were not enough contacts to support jurisdiction.
- Because a majority could not agree on a single legal test, the Court left future disputes over jurisdiction in cases involving national distributors and internet sales to be worked out case by case under existing precedent.
Doctrinal impact
Cases affected by this decision
Limits Asahi Metal Industry Co. v. Superior Court (480 U. S. 102)
The Court resolved Asahi's open question by adopting the narrower, purposeful-availment view over the broader foreseeability approach.
Reaffirms World-Wide Volkswagen Corp. v. Woodson (444 U. S. 286)
The Court relied on this case's rule that mere foreseeability of a product reaching a state is not enough for jurisdiction.