Asahi Metal Industry Co. v. Superior Court of California

480 U.S. 102, 107 S. Ct. 1026, 94 L. Ed. 3d 92 (1987)

 

  • A Taiwanese tire manufacturer (Cheng Shin) used a valve made by a Japanese company (Asahi). One of their tires blew out on a car in California and injured someone.
  • The injured party sued Cheng Shin, and in response Cheng Shin filed a third-party complaint in California against Asahi.
    • Asahi argued that California didn't have jurisdiction, and made a motion to dismiss the complaint.
      • Asahi wasn't located in California, and didn't sell valves there.
  • The California Trial Court denied the motion, Asahi appealed.
  • California Supreme Court affirmed and continued to deny the motion. Asahi appealed.
  • US Supreme Court reversed and found that California does not have jurisdiction over Asahi.
    • There was no majority decision in this case, and different Justices had different reasons for finding that the California Court had jurisdiction.
    • The US Supreme Court found that there was a 5 factor test for to determine if a State could get jurisdiction over a foreign defendant:
      • The burden on the defendant,
      • The interests of the forum State,
      • The interest of the plaintiff,
      • Interstate efficiency, and
      • Interstate policy interests.