J. McIntyre Machinery, Ltd. v. Nicastro
The Supreme Court ruled that New Jersey could not sue a British scrap-metal machine manufacturer over an injury caused by one of its machines, because the company never specifically targeted New Jersey itself, even though it sold nationwide through an independent U.S. distributor.
The fractured decision leaves the rules for suing foreign manufacturers in state court unsettled: four justices wanted a strict rule requiring the company to have deliberately targeted the specific state, two justices reversed on narrower grounds without adopting that broad rule, and three dissenting justices argued that any state where a nationally-marketed product causes injury should be able to hear the case.
“As a general rule, the exercise of judicial power is not lawful unless the defendant “purposefully avails itself of the privilege of conducting activities within the forum State, thus invoking the benefits and protections of its laws.””
The plurality's core test for when a state can exercise jurisdiction over an out-of-state defendant.
How it got here: A New Jersey trial court and the New Jersey Supreme Court held the British manufacturer subject to jurisdiction; the manufacturer asked the U.S. Supreme Court to review that ruling.
The Case in Depth
What happened
Robert Nicastro lost four fingers using a metal-shearing machine at his New Jersey workplace. The machine was made by J. McIntyre Machinery, Ltd., a British company that manufactures scrap-metal equipment in England. McIntyre sold its machines in the United States through an independent distributor, and its representatives attended trade shows around the country, though never in New Jersey itself. Only a handful of its machines ever reached New Jersey.
The question before the Court
Could New Jersey courts hear a lawsuit against a British machine maker whose products reached the state only through an independent nationwide distributor?
The Court's answer
No — a plurality of the Court held that New Jersey could not exercise jurisdiction over the British manufacturer because the company never specifically targeted New Jersey. Selling machines nationwide through an independent distributor, without more, does not show the manufacturer purposefully directed its activities at that particular state, which the plurality said is required before a state court can lawfully hear a case against an out-of-state company.
Two more justices, Breyer and Alito, agreed the result should be reversal, but only because Nicastro hadn't shown enough specific facts connecting the manufacturer to New Jersey under existing precedent — they declined to adopt the plurality's broader rule. Three justices dissented, arguing the manufacturer's deliberate effort to sell throughout the entire United States should make it answerable wherever its product caused injury.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
Injured consumers may find it harder to sue foreign manufacturers in the state where they were hurt if the manufacturer sold only through an independent national distributor rather than directly targeting that state. Foreign companies selling into the U.S. through distributors gain more protection from being sued in any state where their products happen to end up.
What changes now
The New Jersey Supreme Court's ruling allowing the suit to proceed is reversed, meaning Nicastro cannot pursue his product-liability claim against the manufacturer in New Jersey courts. Because no single opinion commanded a majority rationale, lower courts are left to work out how to apply the competing approaches in future cases involving foreign manufacturers and national distribution networks, including newer issues like internet and online sales that this case did not address.
What this does not decide
The plurality opinion does not command a majority rationale, since Justice Breyer's separate opinion reached the same result on narrower grounds. The Court did not decide how personal jurisdiction rules apply to internet sales, sales through intermediaries like Amazon, or other modern commercial arrangements, which Justice Breyer specifically flagged as unaddressed.
Concurrences and dissents
Concurrence — Justice Breyer
Justice Breyer agreed the manufacturer's contacts with New Jersey were insufficient under existing precedent, since there was no regular flow of sales or targeted marketing effort directed at the state. But he declined to join the plurality's broader rule, warning it was unwise to announce sweeping new jurisdictional rules for modern commerce, such as internet sales, without a fuller record and without adopting the New Jersey Supreme Court's opposite extreme of nationwide-distribution-based jurisdiction either.
Dissent — Justice Ginsburg
“the splintered majority today “turn[s] the clock back to the days before modern long-arm statutes when a manufacturer, to avoid being haled into court where a user is injured, need only Pilate-like wash its hands of a product by having independent distributors market it.””Ginsburg's central objection that the ruling lets manufacturers dodge accountability through distributors.
Justice Ginsburg argued that a foreign manufacturer that deliberately sought to sell its products throughout the entire United States, using a national distributor and attending national trade shows, should be subject to suit in whichever state its product actually caused injury. She contended the plurality's approach lets manufacturers evade accountability simply by selling through independent distributors, reviving discredited jurisdictional fictions and departing from International Shoe's fairness principles.
How the Court got there
The legal reasoning, step by step
- The plurality applied the longstanding purposeful-availment test, which asks whether a defendant deliberately took action to gain the benefits and protections of a particular state's laws, making it fair to hale that defendant into that state's courts.
- The plurality rejected the 'stream of commerce' theory that had grown out of a fractured 1987 case, Asahi, reasoning that merely placing a product into nationwide distribution channels with the foreseeable possibility it might end up in a given state does not amount to purposefully targeting that state.
- Applying this to the facts, the plurality found the manufacturer had no office, employees, property, or advertising in New Jersey, and its only connection was that a handful of machines happened to arrive there through an independent distributor's own choices.
- Because the manufacturer's conduct showed an intent to reach the U.S. market generally rather than New Jersey specifically, the plurality concluded there was no purposeful availment of New Jersey and thus no lawful basis for that state's courts to exercise jurisdiction.
- Justice Breyer, providing the decisive votes for reversal, agreed the manufacturer lacked sufficient contacts under existing precedent but declined to adopt the plurality's broader targeting rule, finding it unnecessary to decide how the rule would apply to internet sales or other modern commercial arrangements not presented by this case.
Doctrinal impact
Cases affected by this decision
Limits Asahi Metal Industry Co. v. Superior Court (480 U. S. 102)
The Court rejected Asahi's foreseeability-based 'stream of commerce' reasoning in favor of a purposeful-availment requirement.