Case of the Day: Moseley v. Suzuki Motor of Am., Inc., 2018 U.S. Dist. LEXIS 11609 (D. Idaho Jan. 24, 2018)

Summary:

Plaintiff is the estate of a decedent who died in an accident involving the motorcycle manufactured by defendant Suzuki, distributed through American Suzuki Motor Corporation (which is now defunct.) The motorcycle was originally purchased in Utah, then was resold to an owner in Idaho. The owner lent the decedent to ride the motorcycle, whose brakes allegedly failed and killed the rider. Defendant moved to dismiss.

The court granted the motion, finding there was no personal jurisdiction over the defendant, which is a Japanese corporation. That the defendant operated a subsidiary in Idaho was not sufficient to establish specific jurisdiction. The court also found it notable that the particular motorcycle in this case was purchased in Utah rather than Idaho.

Takeaway:

In this blog's unofficial 50-state survey of the long-arm personal jurisdiction, chalk Idaho into the "not so long" column. There are interesting factual points that may change the court's decision later--for example, what if the motorcycle was purchased in Idaho rather than Utah? But as of now, Idaho should be considered to be a state that follows Nicastro and disavowed the stream of commerce theory.