The United States District Court of Massachusetts recently published a decision regarding the constitutional inquiry for specific personal jurisdiction.[1] In Chouinard v. Marigot Beach and Dive Resort, the court ruled that plaintiffs had not satisfied their burden on the “relatedness” prong of the constitutional personal jurisdiction standard.[2] This case served to tighten the newer, more liberal, relatedness standard created in the United States Supreme Court.
Although case law regarding personal jurisdiction has existed in the United States for a long time, it is, as most constitutionally related law topics are, ever evolving. Specific jurisdiction is determined by a three-part test with the burden on the plaintiff to establish: (1) that the defendant purposefully directed its activities to the forum state; (2) that the plaintiffs’ claims “arise out of or relate” to the defendants’ forum activities; and (3) that the assertion of jurisdiction is reasonable and fair.[3] The second prong of the test is where the following cases exist.
In 2017, the Supreme Court issued an 8-1 opinion in Bristol-Myers Squibb holding that 592 plaintiffs who took the medication Plavix outside of California could not bring suit in California because personal jurisdiction was lacking.[4] This decision raised the standard for personal jurisdiction and made it so that in the future, it may be more difficult to establish. More recently, in 2021, the Supreme Court eased that standard again in a product liability case.
In Ford Motor Co. v. Montana Eighth Judicial District, the Supreme Court issued an 8-0 personal jurisdiction ruling that sided with the plaintiffs in a product liability case. The decision created a new standard for the second prong of the personal jurisdiction test that requires a defendant’s in-state activities to merely “relate to” the plaintiff’s claim. However, this new relatedness standard does not always require a causal connection. This resulted in a lack of clarity around the new standard. This lack of clarity created concern for defendants facing more lawsuits outside their home states, but at the same time, created an avenue where the lower courts can develop case law that defines the standard.
This development of case law is where the Chouinard v Marigot Beach case comes in. The case addresses the standard set in the case law that came before it, noting that to satisfy the relatedness prong, the plaintiff must show that the tort claims “arise out of or relate to” defendants’ contacts with Massachusetts. [5] For the court’s exercise of personal jurisdiction to be constitutional, defendants must have such “contacts” with Massachusetts that maintenance of the suit here is “reasonable” and “does not offend traditional notions of fair play and substantial justice.”[6] The plaintiffs made efforts to establish defendant contacted them through advertising but were ultimately unable to establish enough evidence that the Defendant targeted them in the states to the standard required way in Massachusetts.
Although the court was sympathetic to the plaintiffs’ injuries, it ultimately found that defendant did not do enough to establish contacts in Massachusetts. They found that it would be fundamentally unfair to defendants to allow plaintiffs to maintain suit in Massachusetts. The relatedness requirement ultimately allows court to take into account strength or weakness of plaintiffs’ relatedness showing in assessing fundamental fairness of allowing the suit to proceed.[7]
[1] Chouinard v. Marigot Beach Club & Dive Resort, Civil Action 20-10863-MPK[1] (D. Mass. Mar. 31, 2023)
[2] Id
[3]“Supreme Court Issues Landmark Personal Jurisdiction Decision” https://www.jdsupra.com/legalnews/supreme-court-issues-landmark-personal-9824939/#_edn1
[4] Id
[5] Chouinard v. Marigot Beach Club & Dive Resort, Civil Action 20-10863-MPK[1] (D. Mass. Mar. 31, 2023)
[6] Ford Motor Co. v. Montana Eighth Jud. Dist. Ct., — U.S. —, 141 S.Ct. 1017, 1024 (2021)
[7] Nowak v. Tak How Invest., Ltd., 94 F.3d 708, 712-713 (1st Cir. 1996)
