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 1988, a plaintiff purchased a GT All-Terra Mountain Bicycle from a retail store in Santa Fe, New Mexico. While riding the bicycle in 2003, the front wheel detached from the front fork assembly, causing the plaintiff to suffer serious, permanent injuries. The plaintiff filed a lawsuit against the retailer, the bicycle's manufacturers, and the manufacturer of the bike's frame and fork, alleging negligence in the design, manufacture, assembly, and sale of the bicycle and its components, which led to the accident (paras 2-3).

Procedural History

• District Court of Santa Fe County: The court granted the motion to dismiss for lack of personal jurisdiction over the foreign manufacturer of the bicycle part, concluding that the manufacturer did not have the constitutionally required minimum contacts with New Mexico (para 1).

Parties' Submissions

• Third-Party Plaintiff-Appellant: Argued that the foreign manufacturer of the bicycle part should be subject to personal jurisdiction in New Mexico due to its involvement in the stream of commerce that brought the product to New Mexico (para 4).
• Third-Party Defendant-Appellee: Contended that it had no distributors or clients in New Mexico, did not know where the bicycles incorporating its quick-release mechanisms were sold, and thus did not have the necessary systematic and continuous contacts or purposeful contact with New Mexico to be subject to either general or specific jurisdiction there (para 4).

Legal Issues

• Whether the foreign manufacturer of a bicycle part has sufficient minimum contacts with New Mexico necessary to support personal jurisdiction (para 7).

Disposition

• The Court of Appeals of New Mexico reversed the district court's decision, holding that the foreign manufacturer did have sufficient minimum contacts with New Mexico to justify personal jurisdiction (para 45).

Reasons

• Per Linda M. Vanzi, Judge, with Roderick T. Kennedy, Judge dissenting, and Michael E. Vigil, Judge specially concurring:
  The court found that the foreign manufacturer's actions of placing its product into the stream of commerce with the expectation that it would be purchased by consumers in New Mexico constituted sufficient minimum contacts for specific jurisdiction under the stream of commerce theory as described in World-Wide Volkswagen Corp. v. Woodson (paras 20-34).
  The court determined that exercising jurisdiction over the foreign manufacturer would not offend traditional notions of fair play and substantial justice, considering the manufacturer's economic benefits from the sale of its products in New Mexico and its engagement in activities that targeted the United States market, including New Mexico (paras 35-37).
  The court clarified its stance on personal jurisdiction jurisprudence, particularly regarding the stream of commerce theory, and chose not to follow the competing versions of the theory as presented in Asahi Metal Industry Co. v. Superior Court and J. McIntyre Machinery, Ltd. v. Nicastro, due to their lack of clear majority support (paras 38-44).