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).  The tire went bad in California and injured someone. Cheng Shin filed a third-party complaint in California against Asahi. Asahi claimed California didn't have jurisdiction, and made a motion to dismiss the complaint.
  • 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.
    • The reason why the Supreme Court found this way is highly dependant on which Justice you talk to.
  • The Supreme Court found that there was a 5 factor test for "fair play":
    • burden on the defendant,
    • interests of the forum state,
    • interest of the plaintiff,
    • interstate efficiency, and
    • interstate policy interests.
  • Notice that the case starts with "Justice O'Connor announced the judgment of the Court."  They did not "deliver the opinion of the Court".  That means that there was no majority.
  • For section 2A, O'Connor dissents and tries to reverse the stream of commerce idea from Gray v. American Radiator, but she could not get enough votes.