Bristol-Myers Squibb Co. v. Superior Court of California

In Bristol-Myers Squibb Co. v. Superior Court of California, the U.S. Supreme Court addressed whether California courts could exercise specific personal jurisdiction over the pharmaceutical company for product liability claims brought by non-resident plaintiffs who took Plavix. The company, incorporated in Delaware and headquartered in New York, faced lawsuits from 592 out-of-state residents alongside California residents. The California Supreme Court found jurisdiction based on the company's extensive contacts with the state. However, on June 19, 2017, the U.S. Supreme Court reversed, holding that for specific jurisdiction, the plaintiffs' claims must arise out of or relate to the defendant's in-state activities. Because the non-residents did not purchase or use Plavix in California and their injuries occurred elsewhere, no such connection existed. The 8-1 ruling limited the reach of state courts over out-of-state corporate defendants.

The U.S. Supreme Court, in an 8-1 decision, held that California courts lacked specific personal jurisdiction over the non-resident plaintiffs' claims. The case was reversed and remanded.

Whether a state court can exercise specific personal jurisdiction over a non-resident defendant for claims brought by non-resident plaintiffs that have no connection to the defendant's activities within the forum state.

The ruling significantly tightened the test for specific personal jurisdiction, making it more difficult for plaintiffs to bring mass tort and product liability claims in forums favorable to them. It curtailed forum shopping and limited nationwide class actions in state courts, reinforcing the requirement of a direct link between the forum and the claims.