Blog Post
October 12, 2021
Foreign Manufacturer Dismissed for Lack of Personal Jurisdiction in the Southern District of Indiana
Faegre Drinker on Products
Case
Patterson v. Chiappa Firearms, USA, LTD, No. 1:20-cv-01430-JPH-MG, 2021 WL 4287431 (S.D. Ind. Sept. 21, 2021).
Significance
- First Indiana case to apply the “relate to” standard articulated in Ford Motor Co. v. Mont. Eighth Jud. Dist. Ct., 141 S. Ct. 1017 (2021).
- Rejects a broad, unlimited stream of commerce theory for establishing personal jurisdiction.
- Denied plaintiff jurisdictional discovery, noting that foreign nationals should not be subjected to extensive discovery in order to determine whether personal jurisdiction over them exists.
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