Bristol-Myers Squibb Co. v. Superior Court of Cal., San Francisco Cty.

California courts lack specific jurisdiction over nonresidents’ claims when there is an insufficient connection between the forum and the claims.

Respondent, a pharmaceutical company, is incorporated in Delaware and headquartered in New York. Respondent engages in business activities in other states, such as California. Respondent sells a drug called Plavix in California. A group of plaintiffs, most of whom are not California residents, filed complaints in the California Superior Court, alleging injuries caused by Plavix. The nonresident plaintiffs did not allege that they obtained Plavix from any California source and did not allege that they were injured or treated in California. Respondent asserted a lack of personal jurisdiction and moved to quash service of summons on the nonresidents’ claims. The California Superior Court denied this motion, holding that the California courts had general jurisdiction over Respondent because Respondent engages in extensive activities in California. Following Daimler AG v. Bauman, the California Court of Appeal found that California courts lacked general jurisdiction, but that they had specific jurisdiction over the nonresidents’ claims. The California Supreme Court affirmed and applied a sliding scale approach to specific jurisdiction, concluding that Respondent’s extensive contacts with California permitted the exercise of specific jurisdiction because the claims of the nonresidents were similar to the claims of California residents. The U.S. Supreme Court granted certiorari to decide whether the California courts’ exercise of jurisdiction violates the Due Process Clause of the Fourteenth Amendment. In order for a court to exercise specific jurisdiction over a claim, there must be an affiliation between the forum and the underlying controversy, principally, an activity or an occurrence that takes place in the forum state. The California Supreme Court’s sliding scale approach is inconsistent with precedent because it allows the strength of the required connection between the forum and the claim to be relaxed if the defendant has extensive forum contacts that are unrelated to those claims. The fact that other plaintiffs obtained and ingested Plavix in California, and sustained the same injuries, does not allow California to assert specific jurisdiction over the nonresidents’ claims without identifying any adequate link between the State and the nonresidents’ claims. REVERSED AND REMANDED.