Ford Motor Co. v. Montana Eighth Judicial Dist. Court (19-368)

argument 19-368

Ford Motor Co. v. Montana Eighth Judicial Dist. Court

Supreme Court of the United States 1h 0m 8 speakers 8 chapters transcribed 7 days ago official recording ↗

▲ 0

Transcript

jump: chapters · speakers · find in transcript

Transcript

Transcript generated automatically by AI and may contain errors.

What is the core legal issue about specific jurisdiction in Ford Motor Co. v. Montana?

John G. Roberts 0:00

We'll hear argument next in case 19368, Ford Motor Company versus Montana 8th Judicial District Court and the consolidated case. Mr. Murata?

Unknown 0:13

Thank you, Mr. Chief Justice, and may it please the court. Specific jurisdiction requires that the defendant have engaged in suit-related conduct in the forum state or that have engaged in conduct relevant to the plaintiff's claims in the forum state. If those requirements mean anything, it is that the defendant's forum state conduct must be at least a but-for cause of the plaintiff's claim. Conduct that does not cause a claim is, by definition, irrelevant to the plaintiff's claim. The claims would be the same with or without the conduct. Once the court accepts but-for causation as the minimum, proximate causation follows. A proximate cause standard recognizes that there are some but-for causes that are too attenuated to be a legal cause of the plaintiff's claim and keeps those distant causes from creating jurisdiction.

Unknown 1:04

An approximate cause standard lines up with this court's cases since international shoe and the principles of federalism, fairness, predictability, and administrability that have long governed this court's analysis. Respondent's primary argument that Ford is subject to jurisdiction in Minnesota and Montana because it carried on similar unrelated business there is the same argument this court rejected in Bristol-Myers Squibb. All that respondents add is that they are forum residents injured in the forum state. But the court rejected that argument in Walden when it explained that an injury is, quote, jurisdictionally relevant only insofar as it shows the defendant has formed a contact with the forum state.

Unknown 1:45

And no one claims that respondents' forum state injuries show that Ford has formed contacts with Montana and Minnesota. The vehicles were brought to the forums through the unilateral actions of third parties, and respondents would have been injured wherever they happened to be when the vehicles crashed. In the end, respondents pressed heavily on the notion that Montana and Minnesota have an interest in providing a forum to their injured residents, but that runs afoul of this court's cardinal rule that the due process clause protects defendants, not plaintiffs, and not forum states. Decisions below should be reversed.

John G. Roberts 2:20

Mr. Murata, Ford advertises in all 50 states, right?

Unknown 2:26

It does advertise and market its vehicles to some extent in all 50 states,

John G. Roberts 2:31

yes. Right. So, if somebody is in an accident and they think the vehicle might have had something to do with it, is it enough under your theory for them to say, one reason I bought a Ford was because I saw one of their ads and I was persuaded that they made good cars?

Unknown 2:50

I think that would satisfy but-for causation, Mr. Chief Justice, because the purposeful availment through marketing is in the but-for chain. It may not satisfy proximate causation depending on the nature of the claim. For a routine design defect claim, the mere fact that you saw a Ford ad and were persuaded to buy it has nothing to do with the substance of the claims. By contrast, if your claim is

John G. Roberts 3:14

that... Why is that? I mean, you wouldn't be in the car if you weren't persuaded to buy it. Why doesn't that have a lot to do with the claim?

Unknown 3:23

Well, as Professor Drillmeyer says, if you're telling the story of this car accident, the fact that they saw a Ford ad has no substantive relevance to either the story or to any of the legal elements of the claim. But by contrast, if your claim is that Ford made certain promises to me in that ad, you know, they warranted that the airbags would deploy... and I relied on that promise in buying the Ford vehicle, and they breached that promise, that may satisfy a proximate cause. But what I think the question shows is, but of course here, you don't even have the allegation that they were persuaded to buy the vehicles by the advertisements in the forum states.

John G. Roberts 3:58

No, but it's a hypothetical question. And so if the Ford ad said, you know, we make the safest cars on the road, then any claim of a defect, you would satisfy the jurisdictional requirement.