Alabama Court Asserts Jurisdiction Over Suit Against Chrysler Canada For Allegedly Non-Crashworthy Chrysler 300LX

An Alabama woman was killed when her 2006 Chrysler 300LX was struck on the driver’s side by a tractor trailer. The representatives of her estate sued the manufacturer, claiming that she could have survived the crash if her car had been reasonably crashworthy,  equipped with side curtain airbags and side impact protection, including side/torso airbags. The 300LX had been manufactured by Chrysler Canada.

Chrysler Canada asked the court to dismiss the lawsuit, claiming not to be subject to the Alabama federal court’s jurisdiction. Its position was that it had no physical presence in Alabama: no offices, telephone numbers, bank accounts, or  employees. Chrysler Canada also denied ever seeking business from potential customers in Alabama, since it did not advertise here.

The U.S. District Court for the Northern District of Alabama considered whether it could try the plaintiffs’ claims under the Alabama Extended Manufacturer’s Liability Doctrine (the “AEMLD”), as well as for negligence, wantonness, and breach of warranty, after Chrysler Canada moved to dismiss for lack of personal jurisdiction.

The court examined a long line of precedents regarding jurisdiction based on a defendant’s contacts with the forum where the lawsuit has been brought. Specifically the court looked at different tests as defined by the United States Supreme Court, in such cases as World Wide Volkswagen Corp. v Woodson, 444 U.S. 286 (1980)(insufficient contacts by car manufacturer in injury crash due to lack of foreseeability that putting its products into stream of commerce could result in sales in Oklahoma and subsequent court action there – “stream of commerce test”), Asahi Metal Industry Co. v. Superior Court of Cal., Solano County, 480 U.S. 102 (1987) (no California jurisdiction over motorcycle tire valve manufacturer whose valve’s failure allegedly caused motorcycle accident where manufacturer did not anticipate that its products would be sold in California – “stream of commerce plus” test), and J. McIntyre Mach., Ltd. v. Nicastro, 131 S.Ct. 2780 (2011)( No jurisdiction by New Jersey court over company that manufactured machine that injured plaintiff’s hand where no evidence of intent to market product in state – “stream of commerce plus regular flow” test).

The Alabama court then focused more close to home and zoomed in on how the Eleventh Circuit had applied the Supreme Court precedents to several cases, coincidentally  involving the identical defendant, Chrysler Canada. The court concluded that a “broad stream of commerce” approach gave the Alabama court jurisdiction over Chrysler Canada, for these reasons:

  • The United States market, including Alabama, is Chrysler Canada’s main market;
  • It is where most of the vehicles Chrysler Canada makes are sold;
  • Chrysler Canada is paid for each vehicle it makes, and thus reaps a considerable benefit from this market, which includes Alabama;
  • It is aware that the vehicles it makes are shipped through the dealership channels of Chrysler United States; and
  • At the time it makes a vehicle, it knows the exact location in the United States where each vehicle it makes will be shipped.

The court compared the circumstances in the 300LX case as being most similar to criteria articulated by Justice Sandra Day O’Connor in the Asahi case and found the defendant’s contact with Alabama to satisfy the “something more” she described in the “stream of commerce plus” test. Chrysler Canada designed the 300LX for the market in Alabama and marketed it through a distributor, Chrysler United States, that agreed to serve as its sales agent in Alabama.

The court denied the motion by Chrysler Canada to dismiss plaintiffs’ suit for lack of personal jurisdiction, and the case proceeded in federal court in Alabama.

Even a corporation located in a foreign country may be brought to justice and made to answer for its actions in a court in the United States. To succeed in bringing such a complex case, and to pursue the compensation that you may be entitled to, you need a law firm like Jinks, Crow & Dickson, that is experienced in Alabama automobile design defect cases. Contact Jinks, Crow & Dickson, PC today for a free case evaluation. Or call us toll free in  Union Springs or Montgomery at 888-297-9592.

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Defendants Lose Attempt to Remove Alabama Case to Federal Court After Fatal Failure of Bridgestone Tire, June 23, 2014

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