Lorenzen v. Toshiba Am. Info. Sys.

JOHN J. MCCONNELL, JR., UNITED STATES DISTRICT CHIEF JUDGE

MEMORANDUM AND ORDER

JOHN J. MCCONNELL, JR., UNITED STATES DISTRICT CHIEF JUDGE

This matter arises out of a house fire that occurred at 22 Colonial Road in Coventry, Rhode Island. Edward Lorenzen, four' year-old son, M.L., and two other children, Z.L. and P.L., were home at the time of the fire and while Z.L. and P.L. escaped the fire, Edward and M.L did not and died in the fire.

Plaintiff Kellie Lorenzen filed this lawsuit, alleging that a battery cell, manufactured by Defendant Samsung SDI Co., LTD. (“Samsung”), in a notebook computer manufactured by Toshiba American Information Systems, Inc. (“Toshiba”) failed, causing the Toshiba notebook to emit a large amount of heat and smoke. This heat source, in turn, ignited nearby household combustibles that quickly caused the house to catch fire. Ms. Lorenzen's Second Amended Complaint (ECF No. 42) against both Toshiba and Samsung alleges that a defect in the Samsung lithium-ion batteries in the Toshiba notebook computer caused the fire that killed her husband and son and injured her other children. Samsung now moves to dismiss the Second Amended Complaint on the ground that this Court lacks personal jurisdiction over it. ECF No. 44.

I. SPECIFIC JURISDICTION OVER SAMSUNG^[

A. The Law

For the court to have specific jurisdiction over a defendant, plaintiffs must show “(1) their claims directly arise out of or relate to the defendant's forum activities! (2) the defendant's forum contacts represent a purposeful availment of the privilege of conducting activities in that forum, thus invoking the benefits and protections of the forum's laws and rendering the defendant's involuntary presence in the forum's courts foreseeable! and (3) the exercise of jurisdiction is reasonable.” Knox v. MetalForming, Inc., 914 F.3d 685, 690 (1st Cir. 2019). Earlier this year, the United States Supreme Court decided the latest in a string of cases involving personal jurisdiction over companies engaged in the stream of commerce. Ford Motor Co. v. Montana Eighth Jud. Dist. Ct., 141 S.Ct. 1017 (2021). The Ford Motor case expanded the constitutional reach of personal jurisdiction and held that, “[w]hen a company like Ford serves a market for a product in a State and that product causes injury in the State to one of its residents, the State's courts may entertain the resulting suit.” Ford Motor Co., 141 S.Ct. at 1022.

1. “Arising out of or related to”

For a plaintiffs claims to “arise out of or relate to” a defendant's forum conduct, “‘there must be an affiliation between the forum and the underlying controversy, principally, [an] activity or an occurrence that takes place in the forum State and is therefore subject to the State's regulation.'” Id. at 1025 (quotations omitted), When “a company ‘exercises the privilege of conducting activities within the state'-thus ‘enjoy[ing] the benefits and protections of its laws'-the State may hold the company to account for related misconduct.” Id. (quoting Inti Shoe Co. v. Washington, 326 U.S. 310, 319 (1945)).

The Court finds that the relatedness prong of the personal jurisdiction analysis is satisfied here because Ms. Lorenzen alleges that the lithium-ion batteries in a Toshiba computer caught fire in Rhode Island and injured and killed Rhode Island residents in their home. This explosion in Rhode Island relates to evidence of Samsung's efforts to supply its lithium-ion batteries for incorporation in computers distributed and offered for sale worldwide and throughout the United States. See, e.g., ECF No. 38-4 at 2. This relatedness is more fully set forth in the following section about purposeful availment and in the exhibits Toshiba submitted. ECF No. 38. Therefore, the “arising out of or related to” prong is satisfied.

2. Purposeful Availment

On the topic of the purposeful availment prong, the United States Supreme Court made clear that specific jurisdiction attaches "when a company . . . serves a market for a product in the forum State and the product malfunctions there.” Ford Motor Co., 141 S.Ct. at 1026. In Ford Motor, the Supreme Court relied on forty year-old dicta that:

“[i]f the sale of a product of a manufacturer or distributor ... is not simply an isolated occurrence, but arises from the efforts of the manufacturer or distributor to serve, directly or indirectly, the market for its product in [several or all] other States, it is not unreasonable to subject it to suit in one of those States if its allegedly defective merchandise has there been the source of injury to its owner or to others.”