Russell v. SNFA: Illinois Supreme Court Adopts Expansive Interpretation of Personal Jurisdiction Under a Stream of Commerce Theory in the Wake of McIntyre v. Nicastro
By SHEILA A. SUNDVALL, CHRISTOPHER ALLEN, & SUSAN JACOBY
In its first opportunity to apply the U.S. Supreme Court’s latest decision on the subject of specific personal jurisdiction, J. McIntyre Machinery, Ltd. v. Nicastro, the Illinois Supreme Court recently issued an opinion that will limit the circumstances in which foreign product manufacturers may obtain dismissals on personal jurisdiction grounds in Illinois. Illinois’s highest court found that a foreign component part manufacturer had sufficient minimum contacts with Illinois to satisfy specific jurisdiction requirements where its products were sold in Illinois through a U.S. distributor, despite the fact that the defendant made no direct sales in Illinois and lacked knowledge that its component parts were marketed or sold in Illinois. This decision will increase the significant hurdles facing product manufacturers seeking personal jurisdiction dismissals in Illinois and may increase the likelihood of other state and federal courts exercising personal jurisdiction over foreign manufacturers whose products are sold through U.S. distributors.