J. McIntyre Machinery, Ltd. v. Nicastro

2011-06-27

Headline: Court limits States’ power to sue foreign manufacturers, blocking New Jersey from hearing a product-accident case unless the company purposefully targeted that State

Holding: The New Jersey courts lacked authority to hear the products‑liability suit because the British manufacturer had not purposefully availed itself of New Jersey’s market, so the state’s exercise of jurisdiction violated due process.

Real World Impact:

Makes it harder to sue foreign manufacturers in States they did not specifically target
Reaffirms that firms must purposefully target a State before being sued there

Topics: suing foreign manufacturers, where lawsuits can be filed, product safety lawsuits, state court limits

Summary

Background

A New Jersey worker lost fingers while using a metal‑shearing machine made in England by J. McIntyre and sold in the United States through an independent American distributor. The injured man sued the British manufacturer in New Jersey. The New Jersey Supreme Court held the State could hear the case based on a “stream‑of‑commerce” view that the company should have known its products might reach any State.

Reasoning

The Supreme Court reversed. The majority explained that the Due Process Clause protects people and companies from being sued in a State unless their own conduct shows they purposefully availed themselves of that State’s market. The Court said simply using a national distributor, holding patents, attending trade shows outside New Jersey, or foreseeing that a product might end up in New Jersey does not prove the company targeted that State. Because J. McIntyre did not advertise in, ship to, or otherwise direct its activities at New Jersey, the Court concluded New Jersey lacked authority to decide the claim.

Real world impact

The decision narrows when a State can force a distant or foreign manufacturer to defend in its courts. People injured in a State will still be able to sue when a maker’s own actions show it intended to serve that State’s market, but not when the only ties are indirect distribution or general U.S. marketing. The ruling resolves a decades‑old split about the “stream of commerce,” but it does not answer every modern commerce question.

Dissents or concurrances

Justice Breyer (joined by Justice Alito) agreed with reversing here but urged caution about broad new rules given modern trade. Justice Ginsburg (joined by Justices Sotomayor and Kagan) dissented, arguing the manufacturer had deliberately targeted the U.S. market through its distributor and trade shows and should answer in New Jersey.