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

• The case involves a wrongful death action filed by the family members and the personal representative of a New Mexico resident who died in a single-vehicle rollover accident in Texas. The accident was allegedly caused by tire tread separation on a Bridgestone tire installed on the decedent’s vehicle. The tire, approximately twenty-two years old at the time of the accident, had been installed as the left rear tire on the decedent’s vehicle by a local tire shop in New Mexico, after being initially installed as a spare tire. Plaintiffs allege that the tire's tread separation, which led to the fatal accident, was due to design and manufacturing defects and that Bridgestone negligently failed to notify New Mexico tire shops to remove such tires from service if they are more than ten years old (paras 2-3).

Procedural History

• Chavez v. Bridgestone Americas Tire Operations, LLC (Chavez I), A-1-CA-36442, mem. op. (N.M. Ct. App. Dec. 21, 2018) (nonprecedential): The Court considered whether the district court erred in denying Bridgestone’s motion to dismiss for lack of personal jurisdiction and held that Bridgestone consented to general personal jurisdiction in New Mexico courts by registering to do business in the state (para 4).
• Chavez v. Bridgestone Americas Tire Operations, LLC (Chavez II), 2022-NMSC-006, 503 P.3d 332: The Supreme Court held that the Business Corporation Act does not compel a foreign corporation to consent to general personal jurisdiction and overruled the appellate court's decision in Chavez I, instructing the Court of Appeals to consider whether specific personal jurisdiction over Bridgestone was appropriate (para 5).

Parties' Submissions

• Plaintiffs: Argued that their cause of action arose from Bridgestone’s purposeful contacts with New Mexico, asserting that Bridgestone is subject to specific jurisdiction in New Mexico due to its purposeful availment of the protections and benefits of New Mexico law under a stream of commerce theory (para 6).
• Defendant (Bridgestone): Contended that Plaintiffs failed to allege claims arising from Bridgestone’s purposeful contacts with New Mexico and argued that specific personal jurisdiction is undermined by the fact that the accident occurred in Texas, not New Mexico. Bridgestone also argued that the tire at issue did not come to New Mexico through Bridgestone’s commercial activities (paras 6, 9-10).

Legal Issues

• Whether the district court may exercise specific personal jurisdiction over Bridgestone in the wrongful death claim filed by Plaintiffs (para 5).
• Whether the district court erred in denying Bridgestone’s motion to dismiss based on the lack of specific personal jurisdiction (para 5).

Disposition

• The Court of Appeals held that there was no error in the district court’s denial of Bridgestone’s motion to dismiss and affirmed the decision, concluding that Bridgestone’s purposeful business activities in New Mexico satisfied the minimum contacts requirement for specific personal jurisdiction (para 17).

Reasons

• Per HANISEE, Chief Judge (BOGARDUS and BACA, JJ., concurring): The Court found that Bridgestone established numerous purposeful contacts in New Mexico, including operating an interactive website directed at New Mexico residents, having accounts with local dealerships, and being a frequent litigant in New Mexico courts. These activities demonstrated Bridgestone’s purposeful availment of the privilege of conducting activities within New Mexico, thus satisfying the minimum contacts requirement for specific personal jurisdiction. The Court also concluded that the fatal accident was related to Bridgestone’s contacts in New Mexico, particularly given Plaintiffs’ claims that Bridgestone failed to warn New Mexico service providers about the dangers of using old tires. The Court disagreed with Bridgestone’s argument that the accident’s occurrence in Texas precluded specific personal jurisdiction in New Mexico, citing recent Supreme Court precedents to support its conclusion that the location of the injury alone is not determinative of specific personal jurisdiction (paras 6-16).