J. McIntyre Machinery, Ltd. v. Nicastro
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J. McIntyre Machinery v. Nicastro | |
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Holding | |
A court may not exercise jurisdiction over a defendant that has not purposefully availed itself of doing business in the jurisdiction or placed goods in the stream of commerce in the expectation they would be purchased in the jurisdiction. | |
Court membership | |
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Case opinions | |
Plurality | Kennedy, joined by Roberts, Scalia, Thomas |
Concurrence | Breyer (in judgment), joined by Alito |
Dissent | Ginsburg, joined by Sotomayor, Kagan |
Laws applied | |
U.S. Const. amend. XIV |
J. McIntyre Machinery, Ltd. v. Nicastro, 564 U.S. 873 (2011), is a decision by the United States Supreme Court holding that a court may not exercise jurisdiction over a defendant that has not purposefully availed itself of doing business in the jurisdiction or placed goods in the stream of commerce in the expectation they would be purchased in the jurisdiction.
Background
An accident severed four fingers off the right hand of Robert Nicastro, who was operating a recycling machine used to cut scrap metal.
Decision
In a 6–3 decision, the Supreme Court reversed the New Jersey Court, holding that the state court did not have jurisdiction. Three opinions were delivered, none with a majority of the Justices in support.
According to Justice Kennedy's plurality opinion, there were insufficient facts to show that J. McIntyre Machinery, the British Company, targeted New Jersey specifically. Although the company targeted the United States as a whole, only its distributor targeted the specific states. The stream of commerce theory is insufficient to give rise to jurisdiction without specific targeting of a specific state.
Justice Breyer, joined by Justice Alito, concurred in the judgment on narrower grounds. Rather than announce a broad rule, Breyer determined that based on the facts of this specific case New Jersey did not have jurisdiction because so few machines wound up in the state. However, Breyer was open to the possibility that if many machines were flowing into the state, the state might have jurisdiction even absent specific targeting.
Dissenting, Justice Ginsburg, joined by Justice Sotomayor and Justice Kagan, argued that by targeting the United States as a whole, the petitioner had targeted every state sufficiently to subject itself to New Jersey's jurisdiction.[5][6]
References
- ^ a b J. McIntyre Machinery, Ltd. v. Nicastro, 131 S.Ct. 2780, 2786 (2011).
- ^ Nicastro v. McIntyre Machinery America, Ltd., 987 A.2d 575, 577-78 (N.J. 2010).
- ^ a b Nicastro v. McIntyre Machinery America, Ltd., 987 A.2d 575, 578 (N.J. 2010).
- ^ Nicastro v. McIntyre Machinery America, Ltd., 987 A.2d 575, 577 (N.J. 2010).
- ^ "J. McIntyre Machinery, Ltd. v. Nicastro 564 U.S. ___ (2010- )". Oyez: Chicago-Kent College of Law. Retrieved October 31, 2013.
- ^ "J. McIntyre Machinery, Ltd. v. Nicastro 564 U.S. ___ (2010- )". Justia: The US Supreme Court Center. Retrieved October 31, 2013.
External links
- Text of J. McIntyre Machinery, Ltd. v. Nicastro, 564 U.S. 873 (2011) is available from: Justia Oyez (oral argument audio)