Ethridge v. Samsung SDI
Split Score
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Case Summary
Disposition
Affirmed
The Fifth Circuit, on panel rehearing, reconsidered whether Texas courts may exercise specific personal jurisdiction over Samsung SDI after an 18650 lithium-ion battery injured plaintiff James Ethridge in Texas. Relying on more complete facts that paralleled the Seventh Circuit’s recent Myers decision, the court concluded that Samsung had structured its conduct to avoid consumer sales in Texas and therefore Ethridge’s injuries did not relate to Samsung’s in-state contacts under Ford, and it affirmed the district court’s dismissal for lack of personal jurisdiction.
Circuit Split Identified
Legal Issue
Whether Ford Motor Co. v. Montana Eighth Judicial District Court permits a state to exercise specific personal jurisdiction over a foreign lithium-ion battery manufacturer when an individual battery reaches the forum through third-party resale and injures a resident plaintiff.
Circuit Positions
Ford’s ‘relate to’ test is satisfied; personal jurisdiction exists over foreign battery manufacturers despite their industrial-only sales model.
Ford’s ‘relate to’ test is not satisfied; no personal jurisdiction where the manufacturer structured its conduct to avoid consumer sales and injury arises from unauthorized resale.
Conflict Summary
Circuits are divided on whether the ‘relatedness’ prong of specific personal jurisdiction is satisfied when a manufacturer sells 18650 batteries only to industrial customers yet foreseeable resale leads to injury in the forum state. Some circuits hold that Ford’s flexible standard allows jurisdiction because the injury ‘relates to’ the defendant’s broad market for the product, while other circuits find no jurisdiction where the manufacturer deliberately limits its contacts to exclude the consumer market and the plaintiff’s injury arises from unauthorized resale.