James Ethridge v. Samsung SDI Company, Ltd.

Houston, Texas personal injury lawyers represented the Plaintiff on a product liability claim.



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James Ethridge brought a personal injury lawsuit against Samsung SDI Company, which manufactured a battery that exploded in his pocket. The district court dismissed his complaint for lack of personal jurisdictio

because the Fourteenth Amendment's conceptions of fair play and substantial justice did not allow the State of Texas to exercise personal jurisdiction over Samsung.



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In diversity cases, a federal court "may exercise personal jurisdiction over a nonresident defendant if (1) the long-arm statute of the forum state confers personal jurisdiction over that defendant; and (2) exercise of such jurisdiction by the forum state is consistent with due process under the [Fourteenth Amendment to the] United States Constitution.” Ains-

worth v. Moffett Eng'g, Ltd., 716 F.3d 174, 177 (5th Cir. 2013); see also Fed. R. Civ. P. 4(k)(1)(A). Because the Texas long-arm statute "extends to the limits of the United States Constitution,” Searcy v. Parex Res., Inc., 496 S.W.3d 58, 66 (Tex. 2016), we need consider only the federal constitutional issue.



In International Shoe Company v. Washington, 326 U.S. 310 (1945), the Supreme Court held that Due Process requires a State's exercise of personal jurisdiction to accord with "traditional notions of fair play and substantial justice.” Id. at 316 (quotation omitted). In fleshing out this amorphous stand- ard, the Supreme Court has since recognized two forms of personal jurisdiction: general and specific. Bristol-Myers Squibb Co. v. Superior Ct., 582 U.S. 255, 262 (2017). Because Samsung is neither incorporated in Texas nor has its principal place of business there, there is no general jurisdiction over Sam- sung in Texas. See Daimler AG v. Bauman, 571 U.S. 117, 137–39 (2014).

Reversed and remanded.