The case of Bristol-Myers Squibb Co. v. Superior Court, 137 S. Ct. 1773 (2017), is a landmark United States Supreme Court decision addressing the limits of personal jurisdiction in state courts. The case significantly shaped the law of civil procedure, especially with respect to mass tort litigation involving out-of-state plaintiffs.
The Court held that California courts lacked personal jurisdiction over claims brought by nonresident plaintiffs who did not purchase, ingest, or suffer injury from the drug Plavix in California. By reinforcing the principles established in prior cases, the decision further narrowed the scope of personal jurisdiction that state courts can exercise over out-of-state corporate defendants.
Background of Bristol-Myers Squibb Co. v. Superior Court
Bristol-Myers Squibb (BMS) is a large pharmaceutical company incorporated in Delaware and headquartered in New York. It conducted substantial operations in New York and New Jersey but also engaged in business in California, including the sale of its products. The dispute arose over Plavix, a blood-thinning drug developed, marketed, and sold by BMS.
A large group of plaintiffs filed suit in California state court against BMS, claiming that Plavix had harmed their health. The plaintiffs consisted of 86 California residents and 592 non-California residents. The nonresident plaintiffs had no meaningful connection to California with respect to their claims: they had not obtained Plavix from California sources, had not suffered injury in California, and had not been treated for Plavix-related injuries there.
BMS moved to dismiss the claims of the nonresident plaintiffs, arguing that California courts lacked personal jurisdiction over the company concerning those claims. The California Superior Court denied the motion, reasoning that BMS’s extensive activities in the state—including sales and marketing of Plavix—supported the exercise of jurisdiction.
Following the United States Supreme Court’s decision in Daimler AG v. Bauman, which clarified that general jurisdiction exists only where a corporation is incorporated or has its principal place of business, California courts acknowledged they did not have general jurisdiction over BMS. However, the California Supreme Court upheld jurisdiction on the basis of specific jurisdiction, reasoning that the company’s broad business ties with California sufficed to bring the nonresident plaintiffs’ claims within the court’s authority.
BMS sought review, and the United States Supreme Court granted certiorari to determine whether California courts properly exercised jurisdiction over the claims of the nonresident plaintiffs.
Issues
The central issue before the Court in Bristol-Myers Squibb Co. v. Superior Court was:
- Whether California state courts had personal jurisdiction over the claims of nonresident plaintiffs against BMS, a company incorporated in Delaware and headquartered in New York, when the claims had no connection to California.
Rule of Law
The Supreme Court emphasized that for a state court to assert specific jurisdiction, there must be an affiliation between the forum state and the specific claims at issue. In other words, the defendant’s activities in the forum state must give rise to or relate directly to the plaintiff’s cause of action. General business activity in the state, without a connection to the particular claims being litigated, is not sufficient.
Holding in Bristol-Myers Squibb Co. v. Superior Court
The Supreme Court held that California courts did not have personal jurisdiction over BMS concerning the claims of nonresident plaintiffs. The Court reversed the decision of the California Supreme Court, emphasizing that the claims brought by out-of-state plaintiffs did not arise out of or relate to BMS’s conduct in California.
Reasoning of the Court in Bristol-Myers Squibb Co. v. Superior Court
Justice Samuel Alito delivered the majority opinion, which was joined by all but one of the Justices. The Court’s reasoning rested on the requirements of due process under the Fourteenth Amendment.
The Court explained that specific jurisdiction exists only where there is a direct connection between the forum state and the underlying controversy. The nonresident plaintiffs neither obtained Plavix in California nor were injured or treated there. Further, BMS did not develop, manufacture, label, package, or create marketing strategies for Plavix in California. Thus, there was no adequate link between California and the nonresidents’ claims.
The majority rejected the argument that the presence of California plaintiffs with similar claims, combined with BMS’s extensive unrelated activities in California, could establish jurisdiction for nonresidents. The Court made clear that each plaintiff’s claim must independently satisfy the minimum contacts test for specific jurisdiction.
The Court also noted that the plaintiffs had alternative forums available. They could pursue claims in Delaware, where BMS was incorporated, or New York, where BMS maintained its principal place of business. Alternatively, they could bring individual suits in their home states. The ruling thus did not foreclose their claims but required them to be filed in jurisdictions with proper connections to the controversy.
Importantly, the Court limited its holding to state courts, leaving unresolved whether the same restrictions would apply in federal courts. This reservation left open potential avenues for aggregated litigation at the federal level.
Dissenting Opinion
Justice Sonia Sotomayor authored the sole dissent. She argued that the Court’s decision imposed unnecessary obstacles for injured plaintiffs seeking relief against large national corporations. According to Sotomayor, it is not fundamentally unfair to subject a company that conducts nationwide business to a consolidated suit addressing identical harms.
She emphasized that the majority’s ruling would lead to fragmented litigation, with multiple cases filed across different states, thereby reducing efficiency and increasing costs for both plaintiffs and courts. Moreover, she warned that some injured individuals might be deterred from pursuing claims altogether due to the burdens imposed by the jurisdictional restrictions.
Conclusion
Bristol-Myers Squibb Co. v. Superior Court stands as a definitive statement by the United States Supreme Court on the constitutional limits of personal jurisdiction in state courts. The Court ruled that nonresident plaintiffs cannot sue an out-of-state corporation in a state where their claims have no connection, even if the company engages in significant business activities there.
The decision reflected the Court’s continuing effort to refine jurisdictional principles in line with due process, while Justice Sotomayor’s dissent highlighted the potential inequities and inefficiencies created by this restrictive approach.
This case continues to serve as essential precedent in personal jurisdiction jurisprudence, shaping how courts and litigants approach multi-state disputes involving corporate defendants.