Asahi Metal Industry Co. v. Superior Court, 480 U.S. 102 (1987)

Facts

Zurcher was driving his motorcycle when he lost control and collided with a tractor. Zurcher was severely injured and his wife died. Zurcher claimed product liability against Cheng Shin, the manufacturer of the tube, claiming a loss of air and explosion from the rear tire. Cheng Shin filed an indemnification action against Asahi, who manufactured the valve stem.

Procedural History

Zurcher’s claims were settled leaving only Cheng Shin’s indemnity action against Asahi. Asahi moved to quash the service of summons arguing California could not exert jurisdiction. The Superior Court denied the motion to quash stating that “Asahi obviously does business on an international scale.” The Supreme Court granted certiorari.

Issue(s)

Did the California Superior Court err in denying the motion to quash on the grounds that Asahi does business on an international scale?

Holding(s)

Yes. The facts of the case did not establish minimum contacts such that the exercise of personal jurisdiction is consistent with fair play and substantial justice.

Reasoning/Analysis

The court offered two rationales for finding the California court’s error. First, one group found that Asahi, although placing their products into the stream of commerce, did not directly do so in California. A finding of minimum contacts must come by an action of the defendant purposefully directed toward the forum state. Second, the other group found Asahi did not meet the several factors used to determine reasonableness of the exercise of jurisdiction.

Judgment/Outcome

The court reversed and remanded the judgment of the California Superior Court.

Concurring Opinions/Dissenting Opinions/Comments

Brennan concurred with part two of the opinion regarding reasonableness and disagreed with part one arguing that injecting goods into a stream of commerce should suffice. Stevens also concurred with part two and felt that because part two had been met, it was not necessary to analyze part one. He also argued the court misapplied the facts arguing the volume of deliveries to Cheng Shin would constitute purposeful availment.