Close Enough: Horseshoes, Hand Grenades, and Specific Personal Jurisdiction

How close a connection does there need to be between a lawsuit and the defendant’s in-state activities for specific personal jurisdiction to apply? The Supreme Court issued a decision on that issue today in Ford Motor Co. v. Montana Eighth Judicial District Court and Ford Motor Co. v. Bandemer. The Court held the connection here was close enough: These were product-liability suits in which Ford served the states’ market for the products and the products caused in-state injury to the plaintiffs, who were state residents. That sufficed, the Court held, even if the defendant’s in-state conduct did not cause the plaintiffs’ claims. Justice Kagan wrote the majority opinion for five Justices, while Justice Alito and Justice Gorsuch (the latter joined by Justice Thomas) penned concurrences in the judgment. (Justice Barrett did not participate.)

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