Asahi Metal Industry Co. v. Superior Court of Cal., Solano Cty. (1986)
- Docket
- 85-693
- Decided
- 1986-01-01
Summary
Question: Does the Superior Court of California, Solano County have jurisdiction over the Asahi Metal Industry Company under the Due Process Clause of the Fourteenth Amendment? Conclusion: No. Justice Sandra Day O'Connor delivered the unanimous opinion of the Court. The Court held that the state must show that the defendant company purposefully established "minimum contacts" by directing products toward a particular state. Although Asahi placed its products in a stream of commerce that eventually led to California, there was no evidence that the company marketed or in any way anticipated sales in California. The Court also held that the jurisdiction of the California court would be unreasonable for Asahi, given the distance and the fact that this dispute is purely between Asahi and Cheng Shin. The state of California had only a slight interest in this case that did not outweigh the burden on Asahi. Justice William J. Brennan, Jr. concurred in part and concurred in the judgment. He agreed with the decision of the Court that the California jurisdiction would place an unfair and unreasonable burden on Asahi, but he disagreed with the holding that Asahi did not purposefully interact with the California market. He argued that the ""stream of commerce"" is both predictable and profitable for companies, and the benefits of sales balance the potential burden of litigation. Justices Byron R. White, Thurgood Marshall, and Harry A. Blackmun joined in the concurrence in part and in the judgment. In his opinion concurring in part and concurring in the judgment, Justice John Paul Stevens argued that the examination of whether or not Asahi had established ""minimum contacts"" was unnecessary. The test of minimum contacts only becomes relevant once a reasonable burden has been established. He also argued that the Court misapplied the test by not recognizing that such a high volume of Asahi parts reaching California can only be the result of purposeful business. Justices Byron R. White and Harry A. Blackmun joined in the partial concurrence and concurrence in judgment.