5 Classic Civil Procedure Cases Made Easy for 1Ls
Hello, there, 1Ls! It's time for civil procedure -- a class you'll either love or hate. By the end of this course, if you hear "sufficient minimum contacts" one more time, you're going to want to strangle someone.
To help lower the tension in the room, here are five "classic" civil procedure cases. They all involve personal jurisdiction, so there's a hint for what's likely to be important on the final exam.
1. Pennoyer v. Neff (SCOTUS 1878)
Your casebook had better preface this classic case with Mitchell v. Neff or you're going to be really lost. Marcus Neff hired an attorney, John Mitchell, to help him purchase land in Oregon. Neff got the property but never paid Mitchell. Mitchell sued Neff, but Neff was nowhere to be found. Mitchell won a judgment and levied it against Neff's newly acquired land. Mitchell then assigned the case to Sylvester Pennoyer -- and finally we've arrived at the current case. (Though the story is much more interesting than this.)
Neff wanted the judgment against him reversed because the property was never attached prior to the start of the litigation, meaning the court never had jurisdiction over it, or jurisdiction over him. The Supreme Court agreed and returned the property to Neff. Much of this case isn't relevant anymore, but it's a classic nonetheless.
2. International Shoe v. Washington (SCOTUS 1945)
The state of Washington levied a tax on businesses operating in the state. International Shoe was headquartered in Delaware and Missouri; it had only about a dozen salesmen in Washington. When Washington sued International Shoe over the unpaid taxes, the issue was whether Washington was the right forum. International Shoe established the modern standard of "sufficient minimum contacts" for personal jurisdiction. Because International Shoe conducted business in Washington, suing it there did not "offend traditional notions of fair play and substantial justice." Repeat that phrase kids, it's a classic in and of itself.
3. Gray v. American Radiator (Illinois Supreme Court 1961)
Poor Mrs. Gray was injured when her radiator exploded. She sued the radiator manufacturer and the manufacturer of one of the components. The court ruled that Titan Valve Company, an out-of-state corporation, could be sued in Illinois because it knew, and presumed, that there was a substantial chance its products would be incorporated into water heaters sold in Illinois.
4. World Wide Volkswagen v. Woodson (SCOTUS 1980)
The Woodsons bought a car at Seaway, a Volkswagen dealership in New York and were involved in a car accident in Oklahoma. They sued Seaway, the manufacturer, Volkswagen of America, and World Wide Volkswagen. Could Seaway, a New York dealership, really be dragged into court in Oklahoma? Here, the court brought a new concept to personal jurisdiction: "purposeful availment." The fact that Seaway sold cars, which could be driven anywhere, didn't mean that consented to being sued anywhere in the country. Because Seaway otherwise had nothing to do with Oklahoma, it wasn't foreseeable that it would be haled into court there.
5. Asahi Metal Industry v. Superior Court (SCOTUS 1986)
Gary Zurcher was injured when his motorcycle tire failed. He sued the Taiwanese manufacturer of the tire tube, which cross-complained against Asahi, the Japanese manufacturer of the tire tube's valve. The court in this case further refined the limits of corporate personal jurisdiction. It held that awareness that a product would enter the forum state in the stream of commerce wasn't enough to confer jurisdiction; the defendant had to purposefully direct its product to the forum state. Because Asahi made little metal valves that ultimately ended up all over the place, it didn't specifically direct its conduct at California.
- Sin, Scandal and Substantive Due Process: Personal Jurisdiction and Pennoyer Reconsidered (University of Richmond School of Law)
- No Personal Jurisdiction on Corp. by Serving Executive: 9th Cir. (FindLaw's US Ninth Circuit Blog)
- 5 Classic Criminal Law Cases Made Simple for 1Ls (FindLaw's Greedy Associates)
- 5 Classic Torts Cases Made Simple for 1Ls (FindLaw's Greedy Associates)
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