Bristol-Myers Squibb Co. v. Superior Court of California, San Francisco County, 137 S. Ct. 1773 (U.S. 2017)
Bristol-Myers Squibb Co. v.
May a state court exercise specific personal jurisdiction over a nonresident defendant for claims by nonresident plaintiffs that lack a causal or relational connection to the defendant's forum contacts, based solely on the defendant's extensive forum activities and the similarity of the nonresidents' claims to those of resident plaintiffs?
Specific personal jurisdiction requires that the suit arise out of or relate to the defendant's contacts with the forum state; there must be an affiliation between the forum and the underlying controversy, principally an activity or occurrence that takes place in the forum and is thus subject to the state's regulation. The relationship must be based on the defendant's own suit-related contacts with the forum, not the plaintiff's contacts or the defendant's contacts with persons who reside there. A defendant's extensive forum contacts cannot, under a "sliding scale," substitute for or relax the required connection between the forum and each specific claim. General jurisdiction exists only where a defendant is "at home," typically its place of incorporation or principal place of business.
No. California courts lacked specific personal jurisdiction over the nonresident plaintiffs' claims against BMS because those claims did not arise out of or relate to BMS's contacts with California. The similarity between nonresidents' claims and those of California residents, BMS's extensive forum activities, and its contract with a California distributor did not supply the necessary claim-specific link.
BMS is a leading modern authority constraining specific jurisdiction in mass torts and other multi-plaintiff cases. It rejects the notion that strong forum contacts or similarity to resident plaintiffs' claims can substitute for the required nexus between the forum and each plaintiff's claim. The decision limits state-court aggregation of nationwide claims against out-of-state defendants and channels litigation to defendants' home states or the states where each plaintiff's injury occurred. For law students, BMS is essential alongside International Shoe, Walden, Daimler, and Ford. After BMS, courts require a claim-by-claim, plaintiff-by-plaintiff analysis of relatedness. Ford later clarified that "relate to" does not always require strict causation when the plaintiff is injured in the forum and the defendant extensively serves the forum market for the same product line, but BMS continues to bar jurisdiction where nonresident plaintiffs' injuries occurred elsewhere and lack a forum-specific connection.