After suffering injuries in a motorcycle accident in Florida, the rider sued Yamaha, the motorcycle manufacturer. She brought the lawsuit in South Carolina, where she lived. Yamaha sought to dismiss the lawsuit on the basis of a lack of personal jurisdiction—in other words, on the basis that the claims had nothing to do with Yamaha’s connections to South Carolina. The district court agreed with Yamaha and dismissed the case, leaving the plaintiff to file elsewhere (perhaps in Florida, or in the states Yamaha has designated as its home, Delaware or California) if she wanted to sue at all. But before giving up on her lawsuit in South Carolina, she appealed to the Fourth Circuit Court of Appeals.
The case, Wallace v. Yamaha Motors Corp., USA, required the Fourth Circuit to grapple with the application of the U.S. Supreme Court’s most recent specific jurisdiction decision in Ford Motor Co. v. Montana Eighth Judicial District Court, __ U.S. __, 141 S. Ct. 1017 (2021). Yamaha is an early example of the challenges federal courts will face in interpreting Ford, and determining where a company can be sued.
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