''Asahi Metal Industry Co. v. Superior Court'', 480 U.S. 102 (1987), decided on February 24, 1987, was a case decided by the

United States Supreme Court The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...

, in which the court decided whether a foreign corporation, by merely being aware that its

products Product may refer to: Business * Product (business), an item that serves as a solution to a specific consumer problem. * Product (project management), a deliverable or set of deliverables that contribute to a business solution Mathematics * Produ ...

could end up in the forum state and into the American "stream of

commerce Commerce is the large-scale organized system of activities, functions, procedures and institutions directly and indirectly related to the exchange (buying and selling) of goods and services among two or more parties within local, regional, nation ...

" which later caused injuries, satisfied the

minimum contact Minimum contacts is a term used in the United States law of civil procedure to determine when it is appropriate for a court in one state to assert personal jurisdiction over a defendant from another state. The United States Supreme Court has decid ...

necessary to satisfy jurisdictional due process requirements. The court was unanimous in the result, but issued a fractured decision with Associate Justice Sandra Day O'Connor writing for a plurality of the court.

Facts

Asahi Metal Industry Co. was an international corporation based in Japan, which manufactured a

valve A valve is a device or natural object that regulates, directs or controls the flow of a fluid (gases, liquids, fluidized solids, or slurries) by opening, closing, or partially obstructing various passageways. Valves are technically fitting ...

used in the manufacture of motorcycle wheels. These valves were bought by Cheng Shin Rubber Industrial Co., a

Taiwan Taiwan, officially the Republic of China (ROC), is a country in East Asia, at the junction of the East and South China Seas in the northwestern Pacific Ocean, with the People's Republic of China (PRC) to the northwest, Japan to the nort ...

ese

distributor A distributor is an enclosed rotating switch used in spark-ignition internal combustion engines that have mechanically timed ignition. The distributor's main function is to route high voltage current from the ignition coil to the spark plug ...

. One of these valves was alleged to have failed, causing an accident in California. As a result of the accident the driver of the motorcycle sustained serious injuries and his wife, who was riding on the motorcycle as a passenger, was killed. The accident victim sued Cheng Shin in a California state court, and Cheng Shin in turn filed a third-party complaint (impleader) seeking

indemnification In contract law, an indemnity is a contractual obligation of one party (the ''indemnitor'') to compensate the loss incurred by another party (the ''indemnitee'') due to the relevant acts of the indemnitor or any other party. The duty to indemni ...

from Asahi. Asahi contested California's

personal jurisdiction Personal jurisdiction is a court's jurisdiction over the ''parties'', as determined by the facts in evidence, which bind the parties to a lawsuit, as opposed to subject-matter jurisdiction, which is jurisdiction over the ''law'' involved in the ...

over Asahi, but the California courts found jurisdiction based on Asahi's alleged awareness of the international distribution of its products. Specifically, Asahi moved to quash Cheng Shin's summons. The California Superior Court denied the motion but the

California Court of Appeals The California Courts of Appeal are the state intermediate appellate courts in the U.S. state of California. The state is geographically divided along county lines into six appellate districts.

issued a writ of mandamus to the state of California telling them to quash the summons. The

California Supreme Court The Supreme Court of California is the highest and final court of appeals in the courts of the U.S. state of California. It is headquartered in San Francisco at the Earl Warren Building, but it regularly holds sessions in Los Angeles and Sac ...

reversed this decision, leading Asahi to appeal to the United States Supreme Court.

Holding

The Supreme Court applied a five-factor test in determining whether "traditional notions of fair play" would permit the assertion of personal jurisdiction over a foreign (meaning out-of-state) defendant: #What is the burden on the defendant? #What are the interests of the forum state in the litigation? #What is the interest of the plaintiff in litigating the matter in that state? #Does the allowance of jurisdiction serve interstate efficiency? #Does the allowance of jurisdiction serve interstate policy interests? The Court found that in this case, the burden on the defendant was severe based on both the geographic distance and legal dissimilarities between Japan and the United States. Cheng Shin was not a California resident, diminishing California's interest in the case. Cheng Shin also did not show that it would be inconvenienced if the case for indemnification against Asahi were heard in Japan or Taiwan instead of California. Finally, neither interstate efficiency nor interstate policy interests would be served by finding jurisdiction. Because an assertion of jurisdiction would disturb the "traditional notions of fair play and substantial

justice Justice, in its broadest sense, is the principle that people receive that which they deserve, with the interpretation of what then constitutes "deserving" being impacted upon by numerous fields, with many differing viewpoints and perspective ...

," the decision of the California Supreme Court was reversed and the judgment of California Court of Appeal (California's intermediate appellate court) was effectively reinstated.

External links

* {{caselaw source , case = ''Asahi Metal Industry Co. v. Superior Court'', {{ussc, 480, 102, 1987, el=no , courtlistener = , findlaw = https://caselaw.findlaw.com/us-supreme-court/480/102.html , googlescholar = https://scholar.google.com/scholar_case?case=11850432900293030946 , justia =https://supreme.justia.com/cases/federal/us/480/102/ , oyez =https://www.oyez.org/cases/1986/85-693
Asahi Metal Industry Co. v. Superior CourtSupreme Court of the United States
United States Supreme Court cases United States personal jurisdiction case law 1987 in United States case law United States Supreme Court cases of the Rehnquist Court

Facts

Holding

See also

See also

External links