U.S. Supreme Court Distinguishes Bristol-Myers in Finding Required Contacts for Diversity Jurisdiction and Expands What Constitutes a Seizure for Section 1983 Civil Rights Claims

In the first, Ford Motor Credit v. Montana Eight Judicial District Court, et al., the Court ruled that Ford’s contacts with Montana and Minnesota were substantial enough for specific jurisdiction, since the Plaintiffs were residents of those states, used the allegedly-defective products there, and suffered injuries there. The Court rejected Ford’s argument that jurisdiction was only proper if the Company’s conduct in the forum gave rise to the cause of action (the vehicle were manufactured elsewhere, and originally sold to different consumers in other states; only on re-sale did they come to the plaintiffs). The Court reaffirmed its 2017 decision in Bristol-Myers Squibb Co. v. Superior Court of Cal. that there must be some relationship between the plaintiff’s claims and the defendant’s activities in the forum, but there need not be causation for purposes of specific jurisdiction.
 
In the second, Torres v. Madrid, the Court ruled that shooting a suspect in a fleeing car is a “seizure” even if the person does not stop (does not submit and is not subdued) such that the plaintiff could maintain a 1983 claim. In this case, the plaintiff claimed she thought the officers were carjackers and was shot twice as she fled. The Court determined that the officers “seized” Torres by shooting her with the intent to restrain her movement, but did not address the reasonableness of the seizure, the damages caused by the seizure, or the officers' entitlement to qualified immunity.