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Gray v. American Radiator

From lawbrain.com

Gray v. American Radiator, 22 Ill. 2d 432, 176 N.E.2d 761 (1961), is a civil procedure case which held that a defendant who sells products that he knows will be used within a given state may be required to defend an action within that state, if the product sold in fact causes injuries within the state.


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Contents

Summary of Case Facts

Gray (Plaintiff) was injured when a water heater exploded in the state of Illinois. Gray brought suit in Illinois against Titan Valve Manufacturing Company and American Radiator & Standard Sanitary Corporation (Defendant). The suit alleged that the safety valve had been negligently designed for use in the water heater. The water heater was assembled in Pennsylvania by the Defendant. The valve that exploded was manufactured in Cleveland, Ohio by Titan. Titan had no connection to the State of Illinois, except that its valves were used in conjunction with water heaters sold to consumers within the state.

Issue

Whether the Illinois Long-Arm Statute violates the due process guarantees of the United States Constitution.

Holding and Law

No. A defendant who sells products that he knows will be used within a given state may be required to defend an action within that state, if the product sold in fact causes injuries within that state. American Radiator knew that water hearters were being sold in the state of Illinois. Illinois courts are more convenient as the injury occurred there. Witnesses who will testify regarding the extent of the injury are most likely to reside in Illinois, and other evidence is more likely to be found in Illinois. Therefore, Defendant’s connections to the state are sufficient to satisfy due process.

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