Asahi Metal Industry Co. v. Superior Court
Citation: 480 U.S. 102 (U.S. Supreme Court, 1987)
Facts
A California motorcyclist was injured when his tire blew out. He sued Cheng Shin Rubber, a Taiwanese tube manufacturer. Cheng Shin filed a cross-claim against Asahi, a Japanese manufacturer of valve assemblies, which sold components to Cheng Shin knowing they would be incorporated into tires sold worldwide, including in California. Asahi had no offices, employees, or agents in California.
Issue
Whether California could exercise personal jurisdiction over Asahi based solely on its placement of components into the stream of commerce that foreseeably led to their presence in California.
Holding
The Supreme Court unanimously held that California could not constitutionally exercise personal jurisdiction over Asahi. However, the Court was sharply divided on the reason why.
Rule
No majority agreed on the stream-of-commerce standard. Justice O’Connor’s plurality (4 justices) required “stream of commerce plus” — additional conduct by the defendant directed at the forum beyond mere placement into the stream. Justice Brennan’s concurrence (4 justices) held that awareness that products would reach the forum suffices. All nine justices agreed that even if minimum contacts existed, the exercise of jurisdiction would be unreasonable given the burden on Asahi, a foreign defendant, and the minimal interest California had in adjudicating the indemnification dispute.
Significance
Asahi is famous for producing no majority on the stream-of-commerce question, generating lasting uncertainty that was not resolved by the later J. McIntyre Machinery v. Nicastro decision (which also produced no majority). It is taught to illustrate the limits of stream-of-commerce jurisdiction and the importance of the reasonableness/fairness prong of the personal jurisdiction analysis.