J. McIntyre Machinery, Ltd. v. Nicastro

This case arose from a products-liability suit filed in New Jersey state court where Robert Nicastro seriously injured his hand while using a metal-shearing machine manufactured by defendant. The accident occurred in New Jersey, but the machine was manufactured in England, where defendant was incorporated and operated. At issue was whether the New Jersey courts had jurisdiction over defendant, notwithstanding the fact that the company at no time either marketed goods in the State or shipped them there. The Court held that due process protected defendant's right not to be coerced except by lawful judicial power. As a general rule, the exercise of judicial power was not lawful unless defendant "purposefully avails itself of the privilege of conducting activities within the forum State, thus invoking the benefits and protections of its laws." The Court held that there could be exceptions, say, for instance, in cases involving an intentional tort, but the general rule was applicable in this products-liability case, and the so-called "stream-of-commerce" doctrine could not displace it. Therefore, the Court held that the facts did not demonstrate that defendant purposefully availed itself of the New Jersey market and New Jersey was without power to adjudge the rights and liabilities of defendant where its exercise of jurisdiction would violate due process. Accordingly, the judgment of the New Jersey Supreme Court was reversed.