Alabama Federal Court Has Personal Jurisdiction Over Canadian Car Manufacturer That Produced Cars Specifically for Distribution in U.S.

The U.S. District Court for the Northern District of Alabama denied a Canadian car manufacturer’s motion to dismiss for lack of personal jurisdiction in a case brought by the estate of a woman killed in a car crash alleging liability under the Alabama Extended Manufacturer’s Liability Doctrine, negligence, and breach of warranties.  The defendant is headquartered in Canada and has no contact with the State of Alabama other than its cars that are sold there through defendant’s American parent company.  In considering the motion to dismiss for lack of personal jurisdiction, the court explained that the defendant produced specific vehicles for distribution in the United States and knew that some of the vehicles would be sold in Alabama.  The defendant received direct revenues from the sale of vehicles in Alabama and at least indirectly sought to serve the Alabama market.  The court held that regardless of whether the issue is examined under a stream of commerce or a stream of commerce-plus standard (as discussed in Asahi Metal Industry Co. v. Super. Ct. of Cal., 480 U.S. 102 (1987)), or under a broad or narrow stream of commerce approach (as discussed in J. McIntyre Mach., Ltd. v. Nicastro, 131 S. Ct. 2780 765 (2011)), the court has personal jurisdiction over the defendant.