Asahi Metal Industry Co. v. Superior Court
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| Asahi Metal Industry Co. v. Superior Court | ||||||||||
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| Argued November 5, 1986 Decided February 24, 1987 |
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| Holding | ||||||||||
| Considering the international context, the heavy burden on the alien defendant, and the slight interests of the plaintiff and the forum State, the exercise of personal jurisdiction by a California court over Asahi in this instance would be unreasonable and unfair. | ||||||||||
| Court membership | ||||||||||
| Chief Justice: William Rehnquist Associate Justices: William J. Brennan, Jr., Byron White, Thurgood Marshall, Harry Blackmun, Lewis F. Powell, Jr., John Paul Stevens, Sandra Day O'Connor, Antonin Scalia |
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| Case opinions | ||||||||||
| Majority by: O'Connor Joined by: unanimous (part I); Rehnquist, Brennan, White, Marshall, Blackmun, Powell, Stevens (part II-B) Concurrence by: O'Connor (parts II-A, III) Joined by: Rehnquist, Powell, Scalia Concurrence by: Brennan Joined by: White, Marshall, Blackmun Concurrence by: Stevens Joined by: White, Blackmun |
Asahi Metal Industry Co. v. Superior Court, 480 U.S. 102 (1987) was a case decided by the United States Supreme Court, in which the court considered whether a foreign corporation, by merely putting products into the "stream of commerce" which later caused injuries inside the United States satisfied the minimum contact necessary to satisfy jurisdictional due process requirements.
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[edit] Facts
Asahi Metal Industry Co. was a Japanese company, which manufactured a valve used in motorcycle wheels. These valves were bought by Cheng Shin Rubber Industrial Co., a Taiwanese distributor. One of these valves was alleged to have failed, causing an accident in California. The accident victim sued Cheng Shin in a California state court, and Cheng Shin in turn filed a third-party complaint seeking indemnification from Asahi. Asahi contested California's personal jurisdiction over Asahi, but the California courts found jurisdiction based on Asahi's alleged awareness of the international distribution of its products. Specifically, Asahi moved to quash Cheng Shin's summons. The California Superior Court and the California Supreme Court both denied the motion, leading Asahi to appeal to the United States Supreme Court.
[edit] Result
The Supreme Court articulated the five factor test for determining whether "traditional notions of fair play" would permit the assertion of jurisdiction over a foreign (meaning out-of-state) defendant:
- What is the burden on the defendant?
- What are the interests of the forum state?
- What is the interest of the plaintiff?
- Does the allowance of jurisdiction serve interstate efficiency?
- Does the allowance of jurisdiction serve interstate policy interests.
The Court found that in this case, the burden on the defendant was severe based on both the geographic distance and legal dissimilarities between Japan and the U.S. Cheng Shin was not a California resident, and diminishing California's interest in the case. Cheng Shin also did not show that it would be inconvenienced if the case were heard in Japan or Taiwan. Finally, neither interstate efficiency or interstate policy interests would be served by finding jurisdiction.
Because an assertion of jurisdiction would not be "fair play", the California Supreme Court was reversed.
[edit] See also
- World-Wide Volkswagen Corp. v. Woodson (1980) - another Supreme Court case dealing with personal jurisdiction
- List of United States Supreme Court cases, volume 480
