Case Briefs

Erie Railroad Co v Tompkins

U.S. Supreme Court, 304 U.S. 64 (1938)

For a rambling brief see “The dreaded Erie Doctrine” in Notes.

Pennoyer v Neff

U.S. Supreme Court, 95 U.S. 714 (1877)

Issue: Whether a state may exercise personal jurisdiction over a nonresident on the basis of property ownership alone.

Rule: Under the Due Process Clause, a person is only subject to the jurisdiction of a court if (1) they voluntarily appear in the court, (2) is found within the state, (3) resides in the state, or (4) has property in the state that the court has attached (attached to what?).

Policy:

Holding: A state may not exercise personal jurisdiction over a nonresident on the basis of property ownership alone.

Parties: Marcus Neff (plaintiff) (non-resident of Oregon), Sylvester Pennoyer (defendant); J.H. Mitchell (party in original dispute where Mitchell seized property from Neff and transferred it to Pennoyer)

I. Uncontested facts: Neff hired J.H Mitchell for legal work but did not pay Mitchell for his work. Mitchell sued in Oregon state court. Neff was not a resident of the state nor personally served with process (Mitchell published notice of the summons in Oregon). Neff failed to appear in court. The state court entered default judgment against Neff. Shortly thereafter, Neff took title to a tract of land in Oregon. Mitchell had the sheriff seize the land to be sold to satisfy the judgment. Mitchell bought the land at auction and assigned it to Pennoyer. Neff sued Pennoyer (defendant) to recover the property in the United States Circuit Court for the District of Oregon. The lower court concluded that Mitchell’s judgment was invalid due to defects in the affidavit on which the constructive service was based. Pennoyer appealed to the United States Supreme Court.

II. Plaintiff Neff’s factual allegations: Neff alleges that he was not under state jurisdiction of Oregon where he did not reside in Oregon and had no property in Oregon (Neff resided in California).

III. Defendant Pennoyer’s factual allegations: Pennoyer argues that he bought the property from Mitchell and therefore owns the property.

IV. Lower court’s resolution of the fact: The lower court held that the judgment against Neff was void because Neff did not reside in the state and had no property in the state, wherefore the state court had no jurisdiction over Neff when it made the judgment by which Neff had to pay Mitchell. The lower court held that the jurisdiction of the court cannot be made to depend upon facts to be ascertained after it has tried the cause and rendered the judgment. If the judgment be previously void, it will not become valid by the subsequent discovery of property of the defendant, or by his subsequent acquisition of it. [ … ] The contrary is the law: the validity of every judgment depends upon the jurisdiction of the court before it is rendered, not upon what may occur subsequently. Procedural History: Mitchell sued Neff; default judgment against Neff; Mitchell executed judgement and seized Neff’s land, then transferred land to Pennoyer; Neff sued Pennoyer; appellate court ruled in Neff’s favor; Pennoyer appealed, and here we are.

Court’s Reasoning: [The plaintiff asserts] that the judgment in the State court against the plaintiff was void for want of personal service of process on him, or of his appearance in the action in which it was rendered, and that the premises in controversy could not be subjected to the payment of the demand [722] of a resident creditor except by a proceeding in rem; that is, by a direct proceeding against the property for that purpose. [This assertion is sound based on two principles.] One of these principles is, that every State possesses exclusive jurisdiction and sovereignty over persons and property within its territory. [ … ] The other principle of public law referred to follows from the one mentioned; that is, that no State can exercise direct jurisdiction and authority over persons or property without its territory. [ … ] [723] So the State, through its tribunals, may subject property situated within its limits owned by non-residents to the payment of the demand of its own citizens against them; and the exercise of this jurisdiction in no respect infringes upon the sovereignty of the State where the owners are domiciled. [ … ] If the non-resident [724] have no property in the State, there is nothing upon which the tribunals can adjudicate.

Disposition: Judgment affirmed.

International Shoe Co v Washington

U.S. Supreme Court, 326 U.S. 310 (1945)

Issue: Whether due process requires that a defendant not present within the territory of a forum should be subjected to a court’s personal jurisdiction if the defendant has certain minimum contacts with the forum such that the maintenance of the suit does not offend traditional notions of fair play and substantial justice.

Rule: For a defendant not present within the territory of a forum to be subjected to a court’s personal jurisdiction, due process requires that the defendant have certain minimum contacts with the forum such that the maintenance of the suit does not offend traditional notions of fair play and substantial justice. To have minimum contact with the state, the defendant’s contact must be systematic and continuous with the state even if the contact is unrelated to the lawsuit, OR single or occasional acts in a state might be sufficient, depending on their nature and circumstances.

Policy:

Holding: Due process requires that a defendant not present within the territory of a forum be subjected to a court’s personal jurisdiction if the defendant has certain minimum contacts with the forum such that the maintenance of the suit does not offend traditional notions of fair play and substantial justice.

Parties: Washington state (Plaintiff), International Shoe (Defendant)

Facts:

I. Uncontested facts: Washington state commissioner responsible for assessing and collecting contributions to an unemployment fund served a notice of assessment on International Shoe for failure to pay into the fund during the years 1937 to 1940. International Shoe was a Delaware corporation with its principal place of business in Missouri. International Shoe moved to set aside the notice on the grounds that it was not a corporation doing business in Washington, had no registered agent within the state, and was not an employer and did not furnish employment within the state as defined under state law.

II. Plaintiff Washington state’s factual allegations: International Shoe failed to meet their obligation to pay contributions to a Washington state unemployment fund during 1937-1940.

III. Defendant International Shoe’s factual allegations: International Shoe did not have an obligation to pay contributions to a Washington state unemployment fund because the company was based in Missouri, and its activities within WA state were not sufficient to manifest its “presence” there and that in its absence the state courts were without jurisdiction.

IV. Lower court’s resolution of the fact: Denied International Shoe’s motion to set aside the notice.

Procedural History: Unemployment Commissioner > County Court > Washington Supreme Court > U.S. Supreme Court

Court’s Reasoning: The presence of International Shoe’s salespeople in WA and the regular sale of goods to WA residents were sufficient to establish systematic and continuous contacts. This made it reasonable, under traditional notions of fair play and substantial justice, to permit the state to enforce the obligations which International Shoe has incurred there.

Concurrence: Justice Black concurred, noting that states have an unfettered right to tax and permit their citizens to sue corporations whose agents do business in those states. However, Justice Black noted that by tying jurisdiction to minimum contacts, the Court’s decision diminishes the power of states to afford judicial protection to their citizens. Black’s discussion of “natural law” is super interesting:

There is a strong emotional appeal in the words “fair play,” “justice,” and “reasonableness.” But they were not chosen by those who wrote the original Constitution or the Fourteenth Amendment as a measuring rod for this Court to use in invalidating State or Federal laws passed by elected legislative representatives. [ … ] For application of this natural law concept, whether under the terms “reasonableness,” “justice,” or “fair play,” makes judges the supreme arbiters of the country’s laws and practices. [ … ] This result, I believe, alters the form of government our Constitution provides. I cannot agree. … True, the State’s power is here upheld. But the rule announced means that tomorrow’s judgment may strike down a State or Federal enactment on the ground that it does not conform to this Court’s idea of natural justice. [ … ]

Disposition: Decision of WA Supreme Court affirmed.

World-Wide Volkswagen Corp v Woodson

U.S. Supreme Court, 444 U.S. 286 (1980)

Issue: Whether a state court can exercise jurisdiction over a business with no ties to that state, except for the fact that its product ended up causing injury there. (underlying issue whether or not Oklahoma’s long arm jx is compatible with constitutional due process)

Facts:

I. Uncontested facts: harry and kay robinson bought an audi in ny, and went on a journey. They were driving through Oklahoma and another car rammed into the car from behind and the audi caught fire, and kay robinson and two of her children were severely burned. Robinsons brought a products liability suit against three companies (see below)

II. Respondent (formerly plaintiff) Robinson family alleged that the car was badly built

III. Movant Worldwide alleged that the court in Oklahoma (where Robinsons had brought suit) had no Jx over a NY company which did not do business in Oklahoma

Procedural History: Robinsons brought a products liability action in district court for creek county in Oklahoma against three companies:

Audi NSU Auto Union Aktiengesellschaft (Audi);
its importer, Volkswagen of America, Inc. (Volkswagen);
its regional distributor, petitioner World-Wide Volkswagen Corp. (World-Wide); and
its retail dealer, petitioner Seaway.

Seaway and World-Wide entered special appearances,[ … ]claiming that Oklahoma’s exercise of jurisdiction over them would offend the limitations on the State’s jurisdiction imposed by the Due Process Clause of the Fourteenth Amendment.[ … ] District Court rejected this constitutional claim and reaffirmed that ruling in denying petitioners’ motion for reconsideration. [ … ] Petitioners then sought a writ of prohibition in the Supreme Court of Oklahoma [ … ]. The Supreme Court of Oklahoma denied the writ[ … ] USSC granted certiorari, 440 U. S. 907 (1979), to consider an important constitutional question with respect to state-court jurisdiction and to resolve a conflict between the Supreme Court of Oklahoma and the highest courts of at least four other States.[ … ]. USSC reverse.

Court’s Reasoning:

Test: 1. Is asserting jurisdiction over the defendant reasonable? 2. Other factors:

Rule: Foreseeability alone is not sufficient to authorize a state court’s assertion of personal jurisdiction over a non-resident defendant that has no contacts, ties, or relations with the forum state.

Application:

Policy:

Holding:

Disposition:

Asahi Metal Industry Co v Superior Court of CA Solano County

(1987)

Burger King Corp v Rudzewicz

(1984)

Piper Aircraft Co v Reyno

U.S. Supreme Court, 454 U.S. 235 (1981)

Issue: Whether a change in substantive law is reason to dismiss a forum non convenience motion.

Rule: A plaintiff may not defeat a motion to dismiss on grounds of forum non conveniens merely by showing that the substantive law that would be applied in the alternative forum is less favorable to the plaintiffs than that of the present forum.

Facts: Aircraft twin-engine Piper Aztec was

manufactured in PA by Piper Aircraft Co.
fitted with propellors manufactured in Ohio by Hartzell Propellor Inc.
registered in Great Britain
owned and maintained in Great Britain by UK-organized Air Navigation and Trading Co. Ltd.
operated by UK-organized Scottish air taxi service McDonald Aviation Ltd.
crashed in Scotland during flight from Blackpool (England) to Perth (Scotland)
flown by Scottish pilot
all 5 passsengers were Scottish
wreckage of plane now in hangar in Farnsborough, England

British Dept. of Trade suggested mechanical failure of propellors, and pilot error may have contributed to the accident.

Procedural history: Reyno was administrator of passengers’ estates. Sued Piper in CA state court. Case was removed to CA federal court, and then transferred to PA federal district court. Piper and Hartzell moved to dismiss based on forum non convenience. Reyno admitted that was bringing suit in U.S. because laws were more favorable to plaintiffs. Fed district judge ruled that case was overwhelmingly connected to Scotland and should be tried in Scotland.

Reyno appealed. Court of Appeals for the 3rd Circuit reversed, ruling that forum non convenience is inappropriate if the alternative forum’s law is less favorable to the plaintiff.

Piper appealed. U.S. Supreme Court granted cert. Issue was whether a change in substantive law precluded a forum non conveniens dismissal. Justice Thurgood Marshall writing for the USSC ruled no, a change in substantive law is not enough to preclude a forum non conveniens dismissal.

Reasoning: Because the doctrine of forum non convenience is based primarily on convenience, if trial courts engage in complex comparative law analyses, especially when applying foreign law, it defeats convenience that the doctrine is intended to offer.

at 58, the opinion state that “It would be far more convenient, however, to resolve all claims in one trial.” (whose convenience are we talking about?).

A plaintiff’s choice of forum is based on a presumption of legitimacy. This presumption is weakened when the parties who stand to benefit are foreign citizens. If public policy reasons this can be overcome. Private interest factors include (1) access to physical evidence, (2) witnesses, or (3) locations to try the case. Here, private interest factors favored trial in Scotland because

the evidence is located in Great Britain
key witnesses are located in Great Britain

Public factors (the case’s administrative burden on the court system as opposed to the forum’s interest in resolving the case)

the accident occurred in Scotland
the victims were Scottish
most parties were English or Scottish
the complexity of the case would impose a heavy burden on an American court (applying both Scottish law and PA law might confuse the jury)

Justice Thurgood writes that “The Court of Appeals’ approach also poses substantial practical problems [because] at least where the foreign plaintiff named an American manufacturer as defendant, a court could not dismiss the case on grounds of forum non conveniens where dismissal might lead to an unfavorable change in law. The American courts, which are already extremely attractive to foreign plaintiffs, would become even more attractive. The flow of litigation into the United States would increase and further congest already crowded courts.”

“We do not hold that the possibility of an unfavorable change in law should never be a relevant consideration in a forum non conveniens inquiry. Of course, if the remedy provided by the alternative forum is so clearly inadequate or unsatisfactory that it is no remedy at all, the unfavorable change in law may be given substantial weight; the district court may conclude that dismissal would not be in the interests of justice. In these cases, however, the remedies that would be provided by the Scottish courts do not fall within this category”

Holding: A change in substantive law alone is not a reason to dismiss a forum non convenience motion.

Disposition: Reversed. The U.S. Supreme Court supported the PA district court’s dismissal of the motion for forum non convenience.

Dissent: Stevens dissented. He agreed that a forum non convenience should be dismissed because law of the other forum less convenient. He believed however that the case should be returned to the appellate court.

Twombly

Twombly will go here

Iqbal

Iqbal will go here

Ford Motor Company v Montana Eighth Judicial District Court

Brand new SCOTUS rule: 8-0 ruling (March 25, 2021)