The Trial Lawyer Winter 2018 - Page 35

through its Argentinian subsidiary. Id. at 121. Justice Ginsburg, writing for the majority, merely held that California did not have general jurisdiction over the German company for the same reasons that North Carolina did not have general jurisdiction over the European Goodyear entities. Id. at 121-22. The factual differences and limited legal application of this decision should be obvious to the reader at this point. SCOTUS decided Walden v. Fiore, 571 U.S. 277 (2014) the very next month. The plaintiff in Walden was a Nevada resident who brought suit in Nevada against a Georgia police officer based on an alleged unlawful search and seizure occurring at a Georgia airport. Id. 279-80. Justice Thomas authored the majority opinion, merely holding that Nevada lacked specific jurisdiction over the Georgia police officer because the officer had no connection to Nevada. Id. at 290-91. Walden simply stands for the unremarkable proposition that the defendant must have some connection to the forum state. The Georgia police officer’s lack of any connection to Nevada is easily distinguishable from cases involving product manufacturers and others in the distributive chain who have regular business contacts with the forum state through the sale of their products, advertising, dealer and distribution networks, etc. The most recent pertinent decision is Bristol-Myers Squibb Co. v. Superior Court, 137 S. Ct. 1773 (2017), which came out in June 2017. In that case, a group of plaintiffs from across the country filed suit in California for injuries they claimed were caused by the drug Plavix. Id. at 1178. The SCOTUS opinion addressed only those plaintiffs who were not residents of California. Id. And Bristol-Myers Squibb was not a California company. Id. Under these facts, the Court merely held that the