personal jurisdiction; relatedness; relaatedness prong; Ford Motor Co.; Bristol-Meyers Squibb; due process; civil procedure


Ford Motor Co. v. Montana Eighth Judicial District Court marked a watershed in the U.S. Supreme Court’s personal jurisdiction jurisprudence. There, the Court came to a reasonable conclusion: Ford, a multinational conglomerate carrying on extensive business throughout the United States, was subject to personal jurisdiction in states where it maintained substantial contacts that were related to the injuries that prompted the suits. This was so, even though the business it conducted in those states was not the direct cause of the suit. While justifying that conclusion, however, the Court drastically altered the personal jurisdiction inquiry’s relatedness prong, which concerns whether the suit arises out of or relates to the defendant’s contacts with the forum state. The Court’s new framework muddied the water of a doctrine that was already convoluted and, at times, difficult to apply.

This Note examines the application of Ford Motor Co.’s relatedness analysis to different factual scenarios presented to state courts and federal appellate courts. While those courts have focused on several different factors, this Note suggests that the inquiry does not have to be so varied. This Note concludes that the relatedness test should apply narrowly to situations that are factually similar to those in Ford Motor Co. and Bristol-Myers Squibb Co. v. Superior Court. Once the relatedness test is triggered, this Note maintains that a comparison between Bristol-Myers Squibb and Ford Motor Co. reveals that only two factors are determinative: the location of the injury and the extent to which the plaintiff is attempting to buy into the forum.