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16 Duke J. Const. L. & Pub. Pol'y Sidebar 1 (2021)

handle is hein.journals/dukjppsid16 and id is 1 raw text is: 










        FORD MOTOR COMPANY V.
      MONTANA EIGHTH JUDICIAL
    DISTRICT COURT: REDEFINING
    THE NEXUS REQUIREMENT FOR

           SPECIFIC JURISDICTION

                         BRITTANY  DAY*


                         INTRODUCTION
      In Ford Motor Co. v. Montana Eighth Judicial District Court, the
Supreme  Court will have the opportunity to redefine the nexus require-
ment for exercising personal jurisdiction over non-resident defendants.
The Court  will decide whether a national company with an extensive
in-state market for a product is amenable to suit in a forum state under
personal jurisdiction, even if the defendant's contacts within that state
were not the cause of injury. Since International Shoe Co. v. Washing-
ton,' what minimum  contacts are required to find jurisdiction has
continuously evolved, especially because of the ever-growing national
economy.2 Under  one type of personal jurisdiction, specific jurisdiction,
a plaintiff's claims must aris[e] out of or relate[] to the defendant's
contacts with the forum.3 However, the Court has never had the op-
portunity to clarify the outer bounds of that phrase. Ford Motor Co. v.
Montana  Eighth Judicial District Court, consolidated with Ford Motor



Copyright © 2021 Brittany Day
* J.D., Duke University School of Law, 2022. I would first like to thank my parents for their con-
stant love and support. I would also like to thank Rachel Sereix for all of her help throughout the
writing process. Finally, I would like to thank the Duke Journal of Constitutional Law and Public
Policy editorial staff who have devoted time and effort to this publication.
' 326 U.S. 310 (1945).
2 See McGee v. Int'l Life Ins. Co., 355 U.S. 220, 222-23 (1957) (noting the expanding national
economy and increased ability to travel and communicate allowed for an expanded scope for per-
sonal jurisdiction); see also World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 293 (1980)
(stating the historical developments noted in McGee ... have only accelerated since the case
was decided).
' Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408, 414 n.8 (1984).

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