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

• Plaintiffs filed claims against various foreign corporations (the Manufacturers) for personal injury and/or wrongful death allegedly caused by defects in the Manufacturers’ automobiles or automobile components. The incidents occurred in different locations, involving residents and nonresidents of New Mexico, and the specific products involved were not designed, manufactured, or directly sold to Plaintiffs in New Mexico. However, the Manufacturers have marketed and distributed similar products in the state (paras 6-8).

Procedural History

• Court of Appeals decisions: Upheld general personal jurisdiction over the Manufacturers based on their registration to do business in New Mexico, following the precedent set by Werner v. Wal-Mart Stores, Inc., which construed the Business Corporation Act (BCA) to require consent by registration (paras 2, 11, 13).
• Supreme Court of the State of New Mexico: Reversed the Court of Appeals decisions, holding that the BCA does not compel a foreign corporation to consent to general personal jurisdiction by registering to do business in New Mexico (para 54).

Parties' Submissions

• Manufacturers: Argued that the BCA does not require them to consent to general personal jurisdiction in New Mexico. They contended that exercising jurisdiction based on consent by registration would violate their 14th Amendment due process rights, create an unconstitutional condition, and violate the Dormant Commerce Clause. They also argued that the Supreme Court's personal jurisdiction jurisprudence limits general personal jurisdiction to a corporation's state of incorporation and principal place of business (para 3).
• Plaintiffs: Supported the Court of Appeals' decisions, arguing that the BCA requires foreign corporations to consent to general personal jurisdiction as a condition of doing business in New Mexico. They contended that this interpretation aligns with the legislative intent to equalize foreign and domestic corporations under New Mexico law (para 44).

Legal Issues

• Whether the Business Corporation Act requires a foreign corporation to consent to general personal jurisdiction in New Mexico by registering to do business in the state (para 1).
• Whether specific personal jurisdiction can be properly exercised over the Manufacturers in the cases at hand (para 55).

Disposition

• The Supreme Court of the State of New Mexico reversed the Court of Appeals decisions regarding general personal jurisdiction and remanded the cases to the Court of Appeals to consider specific personal jurisdiction over each of the Manufacturers (para 56).

Reasons

• The Supreme Court found that the BCA does not explicitly require a foreign corporation to consent to general personal jurisdiction by registering to do business in New Mexico. The Court concluded that the Legislature did not clearly express an intent to require such consent, and it would be inappropriate to infer consent without clear statutory language. The Court also noted that consent by registration would not promote the legislative intent to equalize foreign and domestic corporations under New Mexico law. The Court overruled the precedent set by Werner v. Wal-Mart Stores, Inc., on statutory construction grounds, stating that Werner's reasoning is outmoded and unsupported by the BCA. The Court emphasized the importance of clear notice for consent to jurisdiction and the constitutional constraints involved. The decision to remand the cases for consideration of specific personal jurisdiction was based on the fact that this issue was preserved but not reached by the Court of Appeals (paras 41-55).