Bristol-Myers Squibb Company v. Superior Court of California for the County of San Francisco, et al.

Summarized by:

  • Court: U.S. Supreme Court Certiorari Granted
  • Area(s) of Law: Civil Procedure
  • Date Filed: January 19, 2017
  • Case #: 16-466
  • Judge(s)/Court Below: 377 P.3d 874 (Cal. 2016)
  • Full Text Opinion

Whether specific jurisdiction requires a causation connection between a defendant's connections with a forum state and the Plaintiff's suit?

Respondents, non-California residents, asserted product-defect claims against Petitioner, a biopharmaceutical company, in California state court regarding the drug Plavix. Petitioners moved to quash service by objecting to personal jurisdiction on the grounds that specific jurisdiction did not exist because the Plavix at issue was not ingested, prescribed, or purchased by Respondents in California nor was it manufactured or designed in California. Essentially, Petitioner argues that Respondents' claims would be the same regardless of Petitioners' contacts with California, and that it must be their "suit-related conduct" that "create[s] a substantial connection with the forum state" in order to establish specific jurisdiction. The trial court found that Petitioner's connections with California were sufficient enough to establish personal jurisdiction and denied the motion. Petitioner petitioned for writ of mandate that was denied by the California Court of Appeals. On appeal to the California Supreme Court, the Court affirmed the Court of Appeals’ denial, finding that general personal jurisdiction did not exist, but that specific jurisdiction applied on a sliding scale and that Petitioner's general business activities in California were sufficient to establish jurisdiction. Petitioner appealed to the United States Supreme Court to resolve the issue of whether specific jurisdiction may be achieved notwithstanding a lack of causation between a defendant's connections with a forum state and the Plaintiff's suit.

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