Asahi Metal v. California

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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).

Reasons

SCOTUS was split 4 to 4 in their reasoning.


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

Stream of commerce & 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.

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