AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• In August 2012, a group of Mexican nationals were traveling in a 1993 Ford E-350 Super Club Wagon from Mexico to Colorado. While on U.S. Highway 54 in Guadalupe County, New Mexico, the vehicle's right rear tire tread separated, causing the vehicle to leave the road and roll three times. This accident resulted in the ejection and subsequent death of two passengers, Javier Ortiz Tarango and Cristian Antonio Romero, and left another, Lauro Cruz, quadriplegic, who later died from his injuries. Several other occupants sustained injuries. The plaintiffs filed a wrongful death and personal injury complaint against Ford Motor Company, Cooper Tire and Rubber Company, and the individual who installed the tire on the van (para 3).

Procedural History

• Appeal from the District Court of Santa Fe County: The district court denied the defendants' motions to dismiss for lack of personal jurisdiction, finding that specific jurisdiction was proper. The court certified the question to the Court of Appeals, which granted the defendants' applications for interlocutory appeal (para 1).

Parties' Submissions

• Defendants (Ford Motor Company and Cooper Tire and Rubber Company): Argued that the district court lacked both general and specific jurisdiction over them because they were not "at home" in New Mexico and the plaintiffs' claims did not arise from the defendants' conduct within the state (para 1).
• Plaintiffs: Provided evidence of the defendants' contacts with New Mexico, including Ford's official dealerships, marketing activities, and website functionalities targeted at New Mexico consumers, as well as Cooper Tire's official dealers, marketing, and litigation presence in New Mexico. They also highlighted both defendants' registration to do business in New Mexico and designation of agents for service of process (paras 5-6).

Legal Issues

• Whether the district court had personal jurisdiction over the defendants based on their business activities and registration to do business in New Mexico (para 1).
• Whether, under Werner v. Wal-Mart Stores, Inc., defendants consented to general jurisdiction in New Mexico courts by registering in compliance with the Business Corporation Act (para 1).

Disposition

• The Court of Appeals affirmed the district court’s denial of the defendants' motion to dismiss for lack of jurisdiction (para 13).

Reasons

• The Court of Appeals, led by Chief Judge Linda M. Vanzi, with Judges J. Miles Hanisee and Stephen G. French concurring, based its decision on several key points:
  The court considered the defendants' arguments against consent by registration to be identical to those in a concurrently filed case, Navarrete Rodriguez v. Ford Motor Co., and rejected them based on the reasoning in that opinion (para 2).
  The court reviewed the legal framework for personal jurisdiction, noting that consent by registration as a basis for jurisdiction was established in the 1917 U.S. Supreme Court case Pennsylvania Fire Insurance Co. of Philadelphia v. Gold Issue Mining & Milling Co. and was not affected by subsequent cases that evolved the doctrine of general jurisdiction (paras 8-9).
  The court found that the defendants had consented to general jurisdiction in New Mexico by registering to do business in the state as required by the Business Corporation Act, as interpreted by Werner v. Wal-Mart Stores, Inc. (paras 10-11).
  The court addressed and dismissed the defendants' argument that applying the Act in this manner violated the dormant Commerce Clause, concluding that New Mexico's interest in adjudicating the matter justified any burden on interstate commerce (para 12).