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New Mexico Federal Court Rules There is No Personal Jurisdiction Over a Foreign Car Maker in New Mexico Personal Injury Suit
A New Mexico federal district court recently dismissed a personal injury lawsuit against a foreign car maker for lack of personal jurisdiction. The underlying case arose after an accident allegedly causing catastrophic physical injuries. A woman was driving a car in New Mexico when she was struck by another vehicle causing the vehicle she was in to roll.
A lawsuit was brought on her behalf and on behalf of her husband against the maker of the car the injured woman was driving in the First Judicial District Court of the State of New Mexico, County of Santa Fe. The plaintiffs sought an award of punitive damages based on causes of action including strict products liability, negligence, breach of an implied warranty, and loss of consortium. The defendant car maker filed a notice of removal, pursuant to which the case was removed from state court to the United States District Court for the District of New Mexico.
Initially the defendant sought dismissal based on allegedly improper service of process and lack of personal jurisdiction. The defendant then withdrew its argument for dismissal based on improper service, resulting in the question of whether there was personal jurisdiction over the defendant being the sole issue for adjudication by the court.
The court explained that specific requirements apply to the exercise of personal jurisdiction over litigants who are not residents of the state in which the court sits. The parties seeking to establish personal jurisdiction, in this case the wife who suffered catastrophic injuries and her husband, bore the burden of proving jurisdiction exists. They were required to satisfy standards for the exercise of personal jurisdiction the U.S. Supreme Court has prescribed based on its interpretation of the Constitution’s due process provisions.
At the first stage of the due process analysis courts are to consider whether the defendant has sufficient minimum contacts with the state in which the defendant has been sued to have reasonably anticipated being haled into court in the state. At the second stage of the due process analysis, courts are to consider whether the exercise of personal jurisdiction over the defendant comports with traditional notions of fair play and substantial justice.
The court reasoned that there were no facts establishing a link between the activities directed by the defendant car maker to New Mexico and the accident forming the basis of the litigation that would support the exercise of personal jurisdiction. According to the court, the injured plaintiff had purchased her car at a used car dealership in New Mexico. Prior to her having title to the car, the car had been titled in California. Focusing on those facts the court concluded that the plaintiffs had not made a prima facie showing of facts supporting the exercise of jurisdiction. The court then denied the plaintiffs the opportunity to take limited discovery concerning jurisdiction on the basis that the plaintiffs purportedly did not articulate with specificity what facts could be obtained through jurisdictional discovery or how the facts would prevent prejudice to them. Why the plaintiffs could reasonably be expected to articulate what facts they could discover before taking discovery is not apparent from the ruling.
If you or a loved one has been injured in an accident, there may be grounds for a financial recovery. An award of damages can assist people who are injured and their families with the medical costs, lost wages, and pain and suffering caused by the accident. To understand more about your case and how it can be pursued to maximize your recoveries, call New Mexico personal injury lawyer Matthew Vance at the Law Office of Matthew Vance, P.C. We provide a free consultation and can be reached at (505) 242-6267 or online.
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