Asahi Metal Industry v. Superior Court
Citation: 480 U.S. 102 (1987)
Facts
A motorcycle accident in California led to a products liability suit. The tire tube valve at issue was manufactured by Cheng Shin (Taiwan), which had bought the valve components from Asahi (Japan). Cheng Shin sought indemnification from Asahi. Asahi knew its components were incorporated into products sold in California but had no other California contacts.
Issue
Does placing a product into the stream of commerce with knowledge that it will reach a particular state constitute minimum contacts with that state?
Holding
The Court was fragmented. On the stream of commerce question, there was no majority: four justices (O’Connor) required “purposeful availment plus” additional conduct targeting the forum; four justices (Brennan) found stream-of-commerce placement sufficient. All nine justices agreed jurisdiction was unreasonable under the circumstances (burden on Asahi, minimal California interest, cross-border complications).
Rule
Stream of commerce split: No majority rule emerged, but courts typically apply one of two approaches:
- O’Connor plurality (plus): defendant must do more than place a product in the stream of commerce — must have additional conduct purposefully directed at the forum (advertising, design for that market, customer service there)
- Brennan plurality: knowledge that product will reach the forum, plus awareness that it is being regularly distributed there, is sufficient
Reasonableness factors (all nine justices agreed): Even if minimum contacts exist, jurisdiction must be reasonable considering: burden on the defendant, forum state’s interest, plaintiff’s interest, interstate judicial efficiency, and shared state policies.
Significance
- Created an unresolved circuit split on the stream-of-commerce test, not resolved until J. McIntyre Machinery v. Nicastro (2011), which also fragmented
- Established the reasonableness test as an independent check on jurisdiction — minimum contacts alone are not sufficient if jurisdiction is fundamentally unreasonable
- Critical for products liability cases with multinational supply chains