Ford Motor Co. v Montana (Eighth Judicial District) was a U.S. Supreme Court case involving personal jurisdiction of a state court in product liability lawsuits. The case, consolidated with Ford Motor Company v Bandemer, involved two product liability lawsuits brought against the Ford Motor Company at the state level related to two drivers' injuries in separate accidents involving Ford's vehicles in Montana and Minnesota. Ford challenged the lawsuits as the vehicles in question were manufactured elsewhere so the states did not have personal jurisdiction over that conduct. The Supreme Court ruled in a 8 to 0 decision that because, under the Due Process Clause, the claims "arise out of or relate to" Ford's business and marketing activities, those activities gave sufficient claim for the states to assert personal jurisdiction over the liability lawsuits.
Background.
Two 2015 accidents involving Ford vehicles were at the basis of the case. In Montana, an accident involving a separated tire tread on a Ford Explorer caused the death of the driver, Markkaya Gullett. In Minnesota, Adam Bandemer had rear-ended a snow plot in a Ford Crown Victoria, causing him to end up in a ditch, but the car's airbags failed to deploy, leading to him to suffer a brain injury.
In both cases, the parties (Gullett's estate and Bandemer) filed suit against Ford over defects in their products in their respective state courts. Ford sought a motion to dismiss both cases on the basis that the state courts lacked personal jurisdiction. Ford argued that the cars themselves were designed and manufactured in other states or in Canada, and only by right of sale ended up in those states. Because of that, there was no relevant connection between their activities of designing and manufacturing the car and the accidents in the states for the state courts to have jurisdiction. These motions were rejected by state district courts and through appeals to both the Montana Supreme Court and Minnesota Supreme Court, upholding lower court rulings that Ford's activities include purposeful promotions and sales of vehicles to their states' residents. Under the Due Process Clause, the courts ruled that the plaintiffs' claims "arise out of or relate to" Ford's business activities in states, thus allowing the state courts to hear these cases.
