What is LawBrain?
It's a living legal community making laws accessible and interactive. Click Here to get Started »

Asahi Metal Industry Co. v. Superior Court

From lawbrain.com

Asahi Metal Industry Co. v. Superior Court, 480 U.S. 102, 107 S. Ct. 1026, 94 L. Ed. 2d 92 (1987), is a civil procedure case in which the Supreme Court held that mere awareness that a product may reach a remote jurisdiction when put in the stream of commerce is not sufficient to satisfy the requirement for minimum contacts under the Due Process Clause.

  • This LawBrain entry is about a case that is commonly studied in law school. You can find, contribute to, and create other common 1L, 2L, and 3L cases in the Law School Cases category. And you can use the Opinon tab above to discuss hypos. For more information on editing, visit the LawBrain edit help page.

Contents

Summary of Case Facts

Defendant Mr. Zurcher, involved in a car accident, alleged that the accident was the result of a defective tire tube which caused his rear wheel to lose air rapidly and explode. Zurcher brought suit and named, as defendants, Cheng Shin, the Taiwanese manufacturer of the tire tube, and Asahi Metal Industry Co., the Japanese tire valve assembly manufacturer. Asahi Metal had sold tire valve assemblies directly to Cheng Shin in Taiwan and Cheng Shin then incorporated the valves into motorcycle tires. Cheng Shin sought indemnity from Asahi Metal in the Zurcher suit and filed a cross claim against Asahi and the other defendants. Zurcher eventually settled out of court with all of the defendants leaving Cheng Shin’s cross claim as the only remaining issue to be decided. Asahi Metal moved to quash the service of summons, claiming that California could not exercise jurisdiction over it because sales to Cheng Shin took place in Taiwan and shipments were sent from Japan to Taiwan. Asahi Metal did no business in California and did not directly import any products to California. Cheng Shin testified that Asahi Metal was told and knew that its products were being sold in California.

Issue

Whether mere awareness that a product may reach a remote jurisdiction when put in the stream of commerce sufficient to satisfy the requirement for minimum contacts under the Due Process Clause.

Holding and Law

No. Minimum contacts require that there be some act by a party which would purposefully avail itself of the privilege of conducting activities within the forum state. Mere awareness that a product may reach a remote jurisdiction when put in the stream of commerce is not sufficient. Asahi’s actions could constitute sufficient minimum contacts if it advertised or marketed its products in California or deliberately designed them to conform to unique California regulations. Asahi however has not engaged in these activities and has done nothing to indicate that it deliberately wants to see its products used in California.

Related Cases and Resources on LawBrain

Contributors

FindLaw AHK, FindLaw John, Sfitzpatrick