Tyler v. Ford Motor Co.
| Decision Date | 17 November 2021 |
| Docket Number | 2:20-CV-584-WKW [WO] |
| Parties | LISA F. TYLER, individually and as personal representative of the estate of Donald P. Tyler, deceased, Plaintiff, v. FORD MOTOR COMPANY and BOBBY FRANK LANE, Defendants. |
| Court | U.S. District Court — Middle District of Alabama |
Before the court is Ford Motor Company's Motion to Dismiss for Lack of Personal Jurisdiction. (Doc. # 12.) The question is whether Ford's actions in Alabama are sufficient to subject Ford to the personal jurisdiction of this court. For the reasons stated below, they are not. Ford's motion to dismiss is therefore due to be granted.
On November 1, 2019, decedent Donald Tyler was driving a 2001 Ford F-250 while towing a trailer. Plaintiff Lisa Tyler was a passenger in the vehicle. While driving on I-65 North in Chilton County, Alabama, Defendant Bobby Frank Lane side-swiped the rear of the F-250, causing Mr. Tyler to lose control and crash into the median cable barrier. (Doc. # 1 at 2.) Plaintiff alleges that both occupants were properly wearing their seatbelts when the F-250 rolled over, landing on the roof of the vehicle. The roof deformed, and the left side pillars collapsed due to the allegedly defective nature of the vehicle. (Doc. # 1 at 2-3.) Decedent Donald Tyler died in the crash, and Plaintiff Lisa Tyler suffered extensive injuries. (Doc. # 1 at 3.) Plaintiff Lisa Tyler brought suit against Ford Motor Company and Bobby Frank Lane on behalf of herself and the estate of decedent Donald Tyler.
Defendant Ford is a Delaware corporation with its principal place of business in Michigan. (Doc. # 1 at 2.) Ford has extensive contacts with the State of Alabama. Through national and Alabama-specific advertisements, it regularly reaches out and encourages Alabama citizens to become Ford owners. Ford partners with hometown staples such as The University of Alabama and Auburn University to target and service the Alabama market. It regularly ships vehicles and replacement parts to Alabama. (Doc. # 20 at 10-13; Doc. # 21-2; Doc. # 21-3; Doc. # 21-5.)
Plaintiff and decedent, however, were not Alabama residents. Plaintiff is- and decedent was-a resident of the state of Florida. (Doc. # 1 at 1; Doc. # 20 at 2.) The vehicle at issue was designed by Ford in Michigan, manufactured in Mexico, and sold to an independent dealership in Tennessee. Plaintiff and decedent purchased their Ford vehicle in Panama City, Florida. The vehicle has never been registered in any state other than Tennessee and Florida. (Doc. # 21-4.) It appears that the F-250 was only present in the state of Alabama because Plaintiff and decedent chose to drive into Alabama that day.
Subject matter jurisdiction is proper under 28 U.S.C. § 1332, as Plaintiff is a citizen of the state of Florida; the decedent was a citizen of the state of Florida; Defendant Ford is a Delaware corporation with its principal place of business in Michigan; Defendant Lane is a citizen of the state of Alabama; and the amount in controversy exceeds seventy-five thousand dollars. The parties do not contest venue. Personal jurisdiction is contested as explained herein.
To survive a motion to dismiss pursuant to Rule 12(b)(2), “the plaintiff bears the burden of establishing a prima facie case of jurisdiction over the movant, nonresident defendant.” Morris v. SSE, Inc., 843 F.2d 489, 492 (11th Cir. 1988). However, the court “must construe the allegations in the complaint as true, to the extent they are uncontroverted by defendant's affidavits or deposition testimony.” Id. Additionally, “where the evidence presented by the parties' affidavits and deposition testimony conflicts, the court must construe all reasonable inferences in favor of the non-movant plaintiff.” Id.
The court may exercise personal jurisdiction over Ford only to the extent authorized by rule or statute, and only so long as that rule or statute is consistent with established due process principles. The constitutional question involves a two-part inquiry. First, the defendant must have sufficient “minimum contacts” with the forum state. Int'l Shoe Co. v. Washington, 326 U.S. 310, 316 (1945). Second, the exercise of jurisdiction must comport with “traditional notions of fair play and substantial justice.” Id. (quoting Milliken v. Meyer, 311 U.S. 457, 463 (1940)). This second part of the inquiry looks at such factors as “the burden on the defendant”; “the forum State's interest in adjudicating the dispute”; “the plaintiff's interest in obtaining convenient and effective relief”; “the interstate judicial system's interest in obtaining the most efficient resolution of controversies; and the shared interest of the several States in furthering fundamental substantive social policies.” WorldWide Volkswagen Corp. v. Woodson, 444 U.S. 286, 292 (1980).
The constitutional limits on personal jurisdiction “protect[] the defendant against the burdens of litigating in a distant or inconvenient forum” and “act[] to ensure that the States through their courts, do not reach out beyond the limits imposed on them by their status as coequal sovereigns in a federal system.” Id.
There are two ways to satisfy this personal jurisdiction test-both requiring different “minimum contacts” and both being at issue in this case. The first is called “general” personal jurisdiction, and the second is called “specific” personal jurisdiction. See Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915, 919 (2011); Burger King Corp. v. Rudzewicz, 471 U.S. 462, 473 n.15 (1985).
General personal jurisdiction, also called “all-purpose” jurisdiction, requires contacts that “are so ‘continuous and systematic' as to render [the Defendant] essentially at home in the forum State.” Goodyear, 564 U.S. at 919 (quoting Int'l Shoe, 326 U.S. at 317). If a defendant is subject to the general jurisdiction of a state, then personal jurisdiction will be satisfied for any suit brought against it in that state, no matter where any suit-related events occurred. Absent exceptional circumstances, corporations will be “at home” only in their state of incorporation and the state of their principal place of business. Daimler AG v. Bauman, 571 U.S. 117, 139 (2014); see also Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408 (1984); Perkins v. Benguet Consol. Min. Co., 342 U.S. 437 (1952). The state of incorporation and the principal place of business are “unique” and “easily ascertainable, ” and opening those fora “afford[s] plaintiffs recourse to at least one clear and certain forum in which a corporate defendant may be sued on any and all claims.” Daimler, 571 U.S. at 137. A corporation is not subject to general jurisdiction anywhere where it “engages in a substantial, continuous, and systematic course of business, ” id. at 138, as conducting business in a state is one thing but making the state the “home” of the corporation is quite another. See id. at 139 n.19.
Specific personal jurisdiction is different. Although it extends beyond the home jurisdictions of the defendant, it does not work for all claims brought against the defendant. First, the contacts with the forum state must rise to the level of “purposeful availment”: “[I]t is essential in each case that there be some act by which the defendant purposefully avails itself of the privilege of conducting activities within the forum State, thus invoking the benefits and protections of its laws.” Burger King, 471 U.S. at 475 (quoting Hanson v. Denckla, 357 U.S. 235, 253 (1958)). The contacts, to be purposeful, must be intentional and not “random, isolated, or fortuitous.” Keeton v. Hustler Mag., Inc., 465 U.S. 770, 774 (1984). Second, if the defendant has deliberately made contact with the forum state, “‘the suit' must ‘arise out of or relate to the defendant's contacts with the forum.'” Bristol-Myers Squibb Co. v. Superior Ct. of Calif., San Francisco Cnty., 137 S.Ct. 1773, 1780 (2017) (alterations adopted) (emphasis omitted) (quoting Daimler, 571 U.S. at 118).
In other words, there must be “an affiliation between the forum and the underlying controversy, principally, an activity or an occurrence that takes place in the forum State and is therefore subject to the State's regulation.” For this reason, “specific jurisdiction is confined to adjudication of issues deriving from, or connected with, the very controversy that establishes jurisdiction.”
Id. (alteration adopted) (citation omitted) (quoting Goodyear, 564 U.S. at 919).
The Supreme Court had occasion to consider its specific jurisdiction test earlier this year in Ford Motor Company v. Montana Eighth Judicial District Court, 141 S.Ct. 1017 (2021). Reaffirming longstanding doctrine, the Court said: “When (but only when) a company ‘exercises the privilege of conducting activities within a state'-thus ‘enjoying the benefits and protection of its laws'-the State may hold the company to account for related misconduct.” Id. at 1025 (alterations adopted) (emphasis added) (quoting Int'l Shoe, 326 U.S. at 319). Ford argued before the Supreme Court, as it previously did here, [1] that specific jurisdiction could only attach where there is a strict causal relationship between Ford's actions and the injury. Id. at 1026. Essentially, Ford argued that specific jurisdiction was limited to the state where Ford sold the complained-of vehicle, or the states where Ford designed and manufactured the vehicle. Id.
The Supreme Court rejected this interpretation. Relying heavily on Daimler's “arise out of or relate to” test, the court said that Ford's activities in the forum state had a significant relationship with the accident, even though they did not...
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