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Asahi Metal Indus. Co. v. Superior Court

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Parties: Plaintiff is Asahi Metal Industry Co., Japanese maker of valves for motorcycle tire tubes.

Facts: Gary Zurcher was riding his motorcycle in California when the rear tire exploded. In the resulting accident, Zurcher's wife died. Zurcher filed a product liability action which named Asahi and Cheng Shin Rubber Industrial Co., the manufacturer of the tire tube.

Procedural History: The defendants eventually settled with Zurcher, but before that happened Cheng Shin filed a cross-complaint against Asahi seeking compensation. Asahi moved to quash the service of summons on the ground of no jurisdiction. Superior Court denied motion to quash summons. Ct of Appeals of Calif. commanded the Superior ct to quash. Supreme ct of calif. reversed and discharged the command from the Ct of Appeal, because jurisdiction was upheld by the due process clause.

Issues:

  1. "Whether the mere awareness on the part of a foreign defendant that the components it manufactured, sold, and delivered outside the United States would reach the forum state in the stream of commerce constitutes 'minimum contacts' between defendant and forum state."
  2. Whether jurisdiction in forum state meets fair play and substantial justice test.

Arguments: Minimum contacts requirement is not met because Asahi only put their products into the stream of commerce. Jurisdiction is also not allowable because of the reasonable and "fair play and substantial justice" test.

Holding: Minimum contact isn't met. Fair play and substantial justice isn't met.

Reasons: Defendant itself didn't do anything that avails itself of benefits of forum state. Actions of the defendant must be purposefully directed at the forum state, more than just placing the product into the stream of commerce.

Judgment: Reversed.