U.S. Supreme Court Holds That State Courts Lack Specific Personal Jurisdiction to Entertain Non-Residents’ Claims for Injuries Not Connected to In-State Conduct

On June 19, 2017, the U.S. Supreme Court issued its ruling in Bristol-Myers Squibb Co. v. Superior Court, which reversed a decision by the California Supreme Court that approved a state court’s assertion of specific personal jurisdiction over personal injury claims by non-residents against a non-resident corporate defendant.

In an opinion written by Justice Alito, the Court held that the California courts’ exercise of personal jurisdiction under the circumstances violated the Due Process Clause of the Fourteenth Amendment to the U.S. Constitution because there was not an adequate connection between the state forum and the specific claims at issue.  The Court did not address the application of its decision in the class action context, and explicitly left open the question of whether the Fifth Amendment similarly restricts the ability of a federal court to exercise specific personal jurisdiction in a similar circumstance.