Bristol-Myers Squibb Co. v. Superior Court of California, San Francisco County, 137 S. Ct. 1773 (U.S. 2017)
Bristol-Myers Squibb v. Superior Court is a cornerstone of modern personal jurisdiction doctrine, particularly for mass-tort and multi-plaintiff litigation.
May a state court exercise specific personal jurisdiction over a nonresident corporate defendant for claims by nonresident plaintiffs when those plaintiffs' claims do not arise out of or relate to the defendant's contacts with the forum state?
Specific (case-linked) 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 therefore subject to the state's regulation. The relationship must be based on contacts that the defendant itself creates with the forum; the defendant's relationship with a third party (or similarity of claims by resident plaintiffs) cannot supply the necessary connection. General (all-purpose) jurisdiction exists only where the defendant is "at home" (typically its place of incorporation and principal place of business). See Goodyear, Daimler, and Walden.
No. California courts lacked specific personal jurisdiction over BMS with respect to the nonresident plaintiffs' claims because those claims did not arise out of or relate to BMS's contacts with California. The California Supreme Court's "sliding scale" approach violated due process.
Bristol-Myers Squibb is pivotal for civil procedure and products-liability practice. It tightens the specific-jurisdiction inquiry by insisting on a plaintiff- and claim-specific connection to the defendant's forum conduct, foreclosing state-court mass actions that bundle nonresident claims lacking a forum nexus. The decision curbs forum shopping and reinforces the limits on state adjudicatory authority announced in Goodyear, Daimler, and Walden. For law students, it is essential for understanding the distinction between general and specific jurisdiction, the defendant-focused nature of the due process analysis, and the practical consequences for litigation strategy in mass torts, class actions, and MDLs. The case also sets the stage for Ford Motor Co. v. Montana (2021), which clarifies that "relate to" does not demand strict but-for causation, while still requiring a meaningful forum connection—something absent in BMS.