The case of Ford Motor Co. v. Montana Eighth Judicial District Court involved two separate accidents, both resulting from alleged defects in Ford cars. Each case was brought in the state where the accident occurred. Ford argued that those state courts could not have personal jurisdiction over Ford because the cars in question were not shown to have been designed, constructed, or originally sold in those states. The appellate courts in both states ruled against Ford.

The Court, in a decision by Justice Kagan, affirmed, applying the standard set forth in International Shoe Co. v. Washington, 326 U.S. 310 (1945), and rejecting Ford’s narrow view of jurisdiction. While recognizing that specific jurisdiction requires a finding that the defendant has engaged in “purposeful availment” as represented by “some act” in that forum that might give the local court jurisdiction over the claim, the Court declined to view that “act” as solely being the one that directly led to the claim in the case. There was no question that Ford sold cars in every state, and Ford was purposefully availing itself in those states even if it did not directly sell the car that malfunctioned.

Justice Alito filed a concurrence suggesting that while the facts of this case were straightforward, the rule in International Shoe may not apply as easily to modern commerce. Justice Gorsuch, joined by Justice Thomas, also concurred, agreeing with the outcome but expressing concern that the majority’s decision made personal jurisdiction harder to parse.

A link to the opinion is here: https://www.supremecourt.gov/opinions/20pdf/19-368_febh.pdf