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Asahi Metal v. California: Difference between revisions
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|date=February 24, 1987 | |date=February 24, 1987 | ||
|subject=Civil Procedure | |subject=Civil Procedure | ||
|facts=* Asahi Metal Industry Co. = "Asahi" = a Japanese company selling tire valves | |appealed_from=California Supreme Court | ||
* Cheng Shin = "Cheng" = a Taiwanese tire company | |facts=*Mr. Zurcher = plaintiff = rider of a motorcycle who was severely injured in an accident which killed his wife in California | ||
* California = the location of the sale of the Taiwanese company's (Cheng) tires | *A defect in the tire valve resulted in a motorcycle accident in California, USA | ||
* | *Asahi Metal Industry Co. = "Asahi" = a Japanese company selling tire valves | ||
|issues=Can the Japanese company (Asahi) be sued for products liability in California because the faulty tire valves were sold in Taiwan? | *Cheng Shin = "Cheng" = a Taiwanese tire company | ||
|holding=All 9 justices agreed that a Superior Court of California couldn't exercise jurisdiction over Asahi (the Japanese company). | *California = the location of the sale of the Taiwanese company's (Cheng) tires | ||
*The sale of Asahi's valves took places in Taiwan | |||
*Asahi knew that Cheng sold its tires worldwide | |||
|procedural_history=*Zurcher sued several defendants including Asahi (based in Japan) & Cheng (based in Taiwan). | |||
*Zurcher sued the companies in the Superior Court of California (California state court).  | |||
*Cheng cross-sued Asahi in the same California forum. | |||
*Zurcher settles his claims for monetary damages. | |||
*Cheng suit for indemnification against Asahi remained in litigation in California. | |||
*Asahi moved to quash the Cheng summons because Asahi argued that California didn't have '''personal jurisdiction''' over the case. | |||
*Asahi lost in the trial court in California. | |||
*Asahi won in the court of appeals. | |||
*Finally, Asahi lost in the Supreme Court of California. | |||
|issues=Is it unreasonable to & un-fair to exercise personal jurisdiction over an alien defendant if the defendant's burden outweighs the plaintiff's & forum's interests in the case? | |||
Can the Japanese company (Asahi) be sued for products liability in California because the faulty tire valves were sold in Taiwan? | |||
|arguments=Asahi argued that it did no business in California. | |||
|holding=<big>Yes. Exercising personal jurisdiction over an alien defendant is unreasonable & unfair if the defendant's burden outweighs the plaintiff's & forum's interests in the litigation.</big> | |||
All 9 justices agreed that a Superior Court of California couldn't exercise jurisdiction over Asahi (the Japanese company). | |||
The dispute between Asahi & Cheng must be adjudicated in Taiwan or Japan. | |||
|judgment=Reversed | |||
|reasons=SCOTUS was split 4 to 4 in their reasoning. | |reasons=SCOTUS was split 4 to 4 in their reasoning. | ||
|rule=Stream of | |||
Sandra O'Connor: Due process forbids courts from exercising personal jurisdiction over defendants under circumstances that offend traditional notions of fair play & substantial justice. | |||
|rule=The Stream of Commerce test shouldn't have been applied to this case according to the justices. | |||
'''purposeful availment''' | |||
Sandra O'Connor = due process requires courts to consider whether a defendant has purposefully established <u>minimum contacts</u> with the forum state. | |||
|case_text_links={{Infobox Case Brief/Case Text Link | |case_text_links={{Infobox Case Brief/Case Text Link | ||
|link=https://www.quimbee.com/cases/asahi-metal-industry-co-v-superior-court | |link=https://www.quimbee.com/cases/asahi-metal-industry-co-v-superior-court | ||
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|link=https://supreme.justia.com/cases/federal/us/480/102/ | |link=https://supreme.justia.com/cases/federal/us/480/102/ | ||
|case_text_source=Justia | |case_text_source=Justia | ||
}}{{Infobox Case Brief/Case Text Link | |||
|link=https://www.oyez.org/cases/1986/85-693 | |||
|case_text_source=Oyez | |||
}} | |||
|case_videos={{Infobox Case Brief/Case Video | |||
|service=YouTube | |||
|id=83GlxaoOZrw | |||
}}{{Infobox Case Brief/Case Video | |||
|service=YouTube | |||
|id=aNXixeP3ApA | |||
}}{{Infobox Case Brief/Case Video | |||
|service=YouTube | |||
|id=IrogxYUdkEw | |||
}}{{Infobox Case Brief/Case Video | |||
|service=YouTube | |||
|id=SbxAlub7syI | |||
}} | }} | ||
}} | }} | ||
Latest revision as of 16:27, May 6, 2024
| Asahi Metal v. California | |
| Court | Supreme Court of the United States |
|---|---|
| Citation | 480 U.S. 102, 107 S.Ct. 1026, 94 L.Ed.2d 92 |
| Date decided | February 24, 1987 |
| Appealed from | California Supreme Court |
| Partially Overturned by | |
| McIntyre v. Nicastro | |
Facts
- Mr. Zurcher = plaintiff = rider of a motorcycle who was severely injured in an accident which killed his wife in California
- A defect in the tire valve resulted in a motorcycle accident in California, USA
- Asahi Metal Industry Co. = "Asahi" = a Japanese company selling tire valves
- Cheng Shin = "Cheng" = a Taiwanese tire company
- California = the location of the sale of the Taiwanese company's (Cheng) tires
- The sale of Asahi's valves took places in Taiwan
- Asahi knew that Cheng sold its tires worldwide
Procedural History
- Zurcher sued several defendants including Asahi (based in Japan) & Cheng (based in Taiwan).
- Zurcher sued the companies in the Superior Court of California (California state court). 
- Cheng cross-sued Asahi in the same California forum.
- Zurcher settles his claims for monetary damages.
- Cheng suit for indemnification against Asahi remained in litigation in California.
- Asahi moved to quash the Cheng summons because Asahi argued that California didn't have personal jurisdiction over the case.
- Asahi lost in the trial court in California.
- Asahi won in the court of appeals.
- Finally, Asahi lost in the Supreme Court of California.
Issues
Is it unreasonable to & un-fair to exercise personal jurisdiction over an alien defendant if the defendant's burden outweighs the plaintiff's & forum's interests in the case?
Can the Japanese company (Asahi) be sued for products liability in California because the faulty tire valves were sold in Taiwan?Arguments
Asahi argued that it did no business in California.
Holding
Yes. Exercising personal jurisdiction over an alien defendant is unreasonable & unfair if the defendant's burden outweighs the plaintiff's & forum's interests in the litigation.
All 9 justices agreed that a Superior Court of California couldn't exercise jurisdiction over Asahi (the Japanese company).
The dispute between Asahi & Cheng must be adjudicated in Taiwan or Japan.Judgment
Reversed
Reasons
SCOTUS was split 4 to 4 in their reasoning.
Rule
The Stream of Commerce test shouldn't have been applied to this case according to the justices.
purposeful availment
Resources
