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State Court Jurisdiction in Product Liability Cases: Plaintiff’s Victory in Ford Motor Co. v. Montana Eighth Judicial District Court et al.

Apr 01, 2021

The United States Supreme Court (“SCOTUS”) recently issued an important ruling for accident victims seeking justice in state courts here in Texas and across the country in consolidated cases originating out of Montana and Minnesota, with an opinion published on March 25, 2021, as Ford Motor Co. v. Montana Eighth Judicial District Court et. al.

  • The importance of these consolidated petitions for review by Ford Motor Company for personal injury plaintiffs and their loved ones was discussed by Jeff Wigington with Bloomberg several months ago; see, “Where to Sue a Car Company for Defects? SCOTUS Might Weigh In,” written by Martina Barash and published by Bloomberg Law on January 9, 2020.

The Impact of Ford Motor Co. v. Montana

In Ford, SCOTUS soundly rejects (in an 8-0 unanimous opinion) Ford’s due process argument in which the car maker urged the states lacked jurisdiction to hear the personal injury claims filed against it by accident victims in Montana and Minnesota. Ford’s defeat is a major victory for plaintiffs who suffer injury due to product defect or defective design.

SCOTUS holds that in products liability cases, a state can exercise personal jurisdiction and hear the claims against the manufacturer in state court when:

(1) the plaintiff resided there;

(2) the underlying accident happened in that state; and

(3) the product manufacturer has purposefully availed itself of the benefits of that state’s marketplace. This is true even if the product at issue in the accident claim was not designed, manufactured, or first sold in that state.

Matter of Specific Jurisdiction

SCOTUS explains in Ford that specific jurisdiction was the issue in these two consolidated cases, and that specific jurisdiction to meet constitutional due process standards existed, acknowledging the importance of “treating defendants fairly and protecting interstate federalism.” It was not necessary for the plaintiffs to show the defendant company had designed, manufactured, or sold its product in the state where the particular vehicle was involved in the accident.

As SCOTUS clarifies, “… because Ford had systematically served a market in Montana and Minnesota for the very vehicles that the plaintiffs allege malfunctioned and injured them in those States, there is a strong "relationship among the defendant, the forum, and the litigation"—the "essential foundation" of specific jurisdiction.”

Note: Justice Kagan wrote the opinion of the Court and was joined by Chief Justice Roberts and Justices Breyer, Sotomayor, and Kavanaugh. Separate Concurring Opinions were written and filed by Justice Alito and Justice Gorsuch. Justice Thomas joined Justice Gorsuch’s opinion. Justice Barrett took no part in the case.

Fighting for Justice: Manufacturer Liability in Injury Claims

Having these cases reach the highest court in the land to confirm the right of state courts to hear the victim’s underlying accident claims is sadly unsurprising. WigRum has extensive experience with product manufacturers, particularly car makers, seeking to avoid accountability for the catastrophic harm that has been caused by their product or part. These controversies sometimes settle; however, all too often manufacturers refuse to accept responsibility for serious personal injuries or death caused by their products. Trials are sometimes necessary where the manufacturer is forced to accept legal liability for the harm suffered by the victim(s). For more, see our Verdicts and Settlements page as well reviewing some of our past cases.

WigRum has the rare distinction of having four nine-figure jury megaverdicts against major corporate defendants, including a $225,000,000.00 verdict against Ford Motor Company.

WigRum’s Jeff Wigington explains:

“This new SCOTUS opinion is a victory for accident victims everywhere who have been hurt or killed due to defective products, especially those involving automotive manufacturers. In both the Montana and Minnesota cases, the plaintiffs were consumers who were injured by the defendant car maker’s products who then sued in their states of residence for harm sustained in accidents that also happened in that same resident state.

“Someone would say – and SCOTUS suggests – that these situations were essentially applications of the longstanding landmark 1980 decision in World-Wide Volkswagen. Nevertheless, Ford Motor Company fought hard to avoid state court liability through a jurisdictional challenge.

“This case is another example of how aggressive and zealous those advocating for victims of product injuries must be willing to fight for justice in these cases. Both cases will now proceed to trial in the state courtrooms of Montana and Minnesota.

“Our good wishes are with both the victims and their counsel in their continued fight for justice against what we know to be tenaciously stubborn defendants who will try to find any possible excuse to avoid liability for the harm their product has caused, no matter how tragic the consequences.”

For more on WigRum’s past experience in dealing with auto manufacturers and product liability claims, please review our discussions involving Vehicle Defects | Defective Car Parts, as well as practice areas dealing with: