Asahi Metal Industry Co. v. Superior Court of Cal., Solano Cty.
94 L. Ed. 2d 92 · Supreme Court of the United States · 1987
Facts
Gary Zurcher was severely injured and his wife killed in a motorcycle accident in Solano County, California, allegedly due to a defective tire tube. Zurcher sued Cheng Shin, the Taiwanese manufacturer of the tube, who then sought indemnification from Asahi Metal Industry Co., a Japanese company that manufactured the valve assembly and sold it to Cheng Shin in Taiwan. Asahi had no direct contacts with California, but Cheng Shin sold finished tubes globally, including in California.
Issue
Does a foreign manufacturer's mere awareness that its components, sold and delivered outside the U.S., would eventually reach the forum state in the stream of commerce constitute sufficient 'minimum contacts' for personal jurisdiction, consistent with due process?
Holding
No. The Supreme Court reversed the California Supreme Court, holding that California courts could not exercise personal jurisdiction over Asahi. The Court found that Asahi lacked the necessary 'minimum contacts' and that exercising jurisdiction would be unreasonable and unfair given the international context and the slight interests of the plaintiff and forum state.
Rule
For personal jurisdiction, the Due Process Clause requires that a defendant purposefully avail itself of the privilege of conducting activities within the forum state. Placing a product into the stream of commerce, without more, is not an act purposefully directed toward the forum state; mere awareness that a product may enter the state is insufficient. Additionally, the exercise of jurisdiction must be reasonable, considering the burden on the defendant, the forum state's interest, the plaintiff's interest, and the international context.
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