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16-466 BRISTOL-MYERS SQUIBB CO. V. SUPERIOR COURT OF CA DECISION BELOW: 377 P.3d 874 CERT. GRANTED 1/19/2017 QUESTION PRESENTED: The Due Process Clause permits a state court to exercise specific jurisdiction over a defendant only when the plaintiff's claims "arise out of or relate to" the defendant's forum activities. Burger King Corp. v. Rudzewicz, 471 U.S. 462, 472 (1985) (citation omitted). The question presented is: Whether a plaintiff’s claims arise out of or relate to a defendant's forum activities when there is no causal link between the defendant’s forum contacts and the plaintiff's claims-that is, where the plaintiff's claims would be exactly the same even if the defendant had no forum contacts. LOWER COURT CASE NUMBER: S221038
The U.S. Supreme Court case Bristol-Myers Squibb Co. v. Superior Court of California, 2016 revolved around the issue of jurisdiction and whether a state court could hear claims related to out-of-state plaintiffs in a mass action lawsuit against pharmaceutical company Bristol-Myers Squibb (BMS). BMS was sued by both Californian residents and non-residents for its drug Plavix, alleging it led to adverse health effects. The company argued that California courts lacked jurisdiction over claims from non-Californians as their injuries did not occur within the state nor were they connected with BMS's activities there. The Supreme Court ruled in favor of BMS, stating that for a court to exercise personal jurisdiction over a defendant, there must be an "affiliation between the forum and the underlying controversy", which wasn't present here regarding out-of-state plaintiffs' claims.
The dissenting opinion in the case of Bristol-Myers Squibb Co. v. Superior Court of California argued that the majority's decision to limit state courts' jurisdiction over out-of-state plaintiffs could potentially undermine public health and safety by making it more difficult for injured parties to seek redress from large corporations. The dissent pointed out that under traditional principles, a corporation can be sued in any state where it has minimum contacts, which includes engaging in substantial business activities or causing harm through its products or services. They contended that this principle should apply even when some plaintiffs are not residents of the forum state, as long as their claims arise from the same course of conduct as those brought by resident plaintiffs. Furthermore, they expressed concern about how this ruling might affect complex litigation involving multiple parties and jurisdictions.