Yamashita v. LG Chem., Ltd.

“For a claim to arise out of a defendant’s forum contacts requires causation, while a claim can relate to those contacts, even absent causation, where, for example, ‘a company . . . serves a market for a product in the forum State and the product malfunctions there.’” Ford Motor Co. v. Mont. Eighth Jud. Dist. Ct., 141 S.Ct. 1017, 1026–27 (2021).

Petitioner purchased a defective battery made by Respondent from a third-party vendor. After the battery exploded and caused injuries, Petitioner filed a product-liability complaint against Respondent for negligence in manufacturing and distribution. Petitioner appealed the district court’s dismissal for lack of personal jurisdiction. Petitioner argued that the facts supported either general or specific personal jurisdiction. Respondents argued while their forum contacts showed purposeful availment, the injuries did not “arise out of or relate to” their contacts with the forum state. The lower court granted Respondents’ motion to dismiss for lack of personal jurisdiction. “For a claim to arise out of a defendant’s forum contacts requires causation, while a claim can relate to those contacts, even absent causation, where, for example, ‘a company . . . serves a market for a product in the forum State and the product malfunctions there.’” Ford Motor Co. v. Mont. Eighth Jud. Dist. Ct., 141 S.Ct. 1017, 1026–27 (2021). While the Court found Respondents’ contacts with the forum state insufficient to establish general personal jurisdiction, they did establish purposeful availment, a foundation for specific personal jurisdiction. The Court reasoned Petitioner failed to show but-for causation between the forum contacts and the injuries. Moreover, the Court reasoned Respondents’ forum contacts were too attenuated to relate to Petitioner’s acquisition of the defective battery. AFFIRMED.