In this products liability case, the Court of Appeals gave a comprehensive analysis of personal jurisdiction. The Court ultimately found that Indiana lacked personal jurisdiction over one of the defendants, NCI, who manufactured a component part of a product that injured an Indiana resident. NCI is a Texas company, has its sole place of business in Cleburne, Texas, and had had no business activities in Indiana for at least six years at the time of the injury. Further, NCI had not made the decision to ship the final product to Indiana.
In a nutshell, Justice Breyer wrote that when a manufacturer in one state places a product into the stream of commerce that causes injury in a second state, a plaintiff must show “‘something more,’ such as special state-related design, advertising, advice, marketing, or anything else” for the second state to acquire personal jurisdiction.
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