Ford Motor Co. v. Montana Eighth Judicial District Court

Two separate cases were consolidated for review. In Montana, Markkaya Gullett died when the tread separated on a tire of her 1996 Ford Explorer, which had been purchased used in Montana. In Minnesota, Adam Bandemer was seriously injured when his 1994 Ford Crown Victoria airbag failed to deploy during an accident. In both cases, the vehicles had originally been sold in other states but were later resold and used in Montana and Minnesota, respectively. Ford had extensive contacts with both states, including dealerships, advertising, and service facilities.

Justice Kagan's majority opinion held that Ford had purposefully availed itself of the privilege of conducting activities in both Montana and Minnesota by systematically serving those markets through dealerships, advertising, and service networks. The claims were related to Ford's in-state activities because Ford cultivated a market for its vehicles in those states, and the plaintiffs' injuries arose from the use of Ford vehicles in those very markets. Requiring strict but-for causation — proof that the plaintiff purchased or the defendant sold the specific product in the forum — would produce arbitrary results and undermine the policies of specific jurisdiction. The Court noted that Ford's own activities had created a strong relationship among the defendant, the forum, and the litigation.

Ford Motor Co. eased concerns that Bristol-Myers Squibb had overly restricted specific jurisdiction. By holding that a 'relate to' nexus is sufficient without strict but-for causation, the Court provided more flexibility for plaintiffs to bring product liability claims in forums where the defendant actively cultivates a market. The decision is particularly significant for cases involving products that move through secondary markets or are resold across state lines.