J. McIntyre Machinery, Ltd. v. Nicastro
Headline: Limits on suing foreign manufacturers: Court reversed New Jersey’s ruling, clarifying that states cannot exercise power to try a foreign maker unless it purposefully targeted that State, narrowing stream‑of‑commerce reach.
Holding:
- Makes it harder to sue foreign manufacturers in states they did not specifically target.
- Limits using national distribution alone to give states power over manufacturers.
- Encourages plaintiffs to sue distributors or in forums with stronger manufacturer contacts.
Summary
Background
Robert Nicastro was injured using a heavy metal‑shearing machine at a New Jersey scrap yard. The machine was made in England by J. McIntyre Machinery, which sold in the United States through an independent U.S. distributor and exhibited at trade shows. Nicastro sued in New Jersey, and the New Jersey Supreme Court said the State could hear the case because the manufacturer’s products entered a nationwide distribution system that might place them in any State.
Reasoning
The Supreme Court reversed. It explained that a state court may exercise jurisdiction only when a company has purposefully availed itself of that State’s market—that is, taken actions showing it intended to invoke or benefit from the State’s laws. Merely placing products into a national distribution stream, attending trade shows, or using a U.S. distributor does not by itself show purposeful targeting of New Jersey. Justice Kennedy’s opinion follows earlier precedents (International Shoe, Hanson, World‑Wide Volkswagen) and rejects a broad foreseeability‑only test from parts of Asahi. Justice Breyer agreed with the outcome but cautioned against an overly broad new rule; Justice Ginsburg dissented, arguing the manufacturer targeted the U.S. market and should be answerable in New Jersey.
Real world impact
The decision makes it harder for injured people to sue foreign makers in a State where the maker did not specifically direct its activities. Businesses that sell abroad through national distributors may face fewer local suits absent state‑specific marketing or sales. Plaintiffs may need to sue distributors, seek forums where the manufacturer had clear contacts, or bring cases where the manufacturer expressly targeted the State.
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