Robinson v. Harley-Davidson Motor Co.

In regards to personal jurisdiction, the appropriate standard for determining if the "arising out of or relating to" requirement supports the exercise of specific jurisdiction is the but-for and foreseeability of litigation test.

Robinson appealed the lower court's dismissal of defendant Grand Teton Cycles, LLC (Grand) for lack of personal jurisdiction. Robinson, an Oregon resident, experienced wobble in the front wheel of her motorcycle while riding through Idaho. Robinson stopped at Grand for repairs. Robinson had heard of the Idaho motorcycle shop through online resources and a brochure. Subsequently, while riding through Wyoming, Robinson experienced wobble in the front wheel, lost control of the motorcycle, and sustained damages. Robinson sued Grand, among others, in Multnomah County Circuit Court. Grand filed a motion to dismiss for lack of personal jurisdiction. The trial court agreed with Grand. Robinson appealed. The Court of Appeals agreed with the trial court and applied the "substantive relevance" test in reaching its conclusion. The Oregon Supreme Court granted review to address whether the substantive relevance test is an appropriate standard under federal law for determining if the "arising out of or relating to" requirement supports the exercise of specific jurisdiction. The Court held that the relatedness standard requires that the litigation must arise out of, or relate to, at least one of a nonresident defendant's activities in this state for Oregon courts to properly exercise jurisdiction. To meet that standard, the activity may not be only a but-for cause of the litigation; rather, the nature and quality of the activity must also be such that the litigation is reasonably foreseeable. Here, the Court did not reach the but-for cause of litigation test in determining whether there is personal jurisdiction over Grand. Instead, the Court found that the nature and quality of Grand's contact with Oregon was not such that it was reasonably foreseeable that Grand would be sued in Oregon for the repairs it made in Idaho.