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First Department Affirms New York Jurisdiction Over Automotive Defendants

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Court: Supreme Court, Appellate Division, First Department (NY)

In this asbestos action, plaintiffs allege that decedent, John Beagan, was exposed to asbestos-containing products while in work areas of New York car dealerships in the 1990s, along with the work areas of car dealerships in his home state of Florida between 1976 and 1986, which led to decedent’s development of mesothelioma.

Plaintiffs filed suit against a number of defendants, including American Honda Motor Co., Inc. and Nissan North America Inc., in the state of New York.

Honda and Nissan each sought summary judgment, arguing that a New York court cannot exercise specific jurisdiction over them as they are non-domiciliaries of the state of New York. Specifically, Honda and Nissan argued, among other things, that plaintiff’s lawsuit violated due process of law because the application of interstate federalism compelled New York to divest itself of personal jurisdiction as jurisdiction over the defendants did not comport with traditional notions of “fair play and substantial justice.” The lower court ultimately disagreed and denied Honda and Nissan’s motions. An appeal to the Supreme Court, Appellate Division, First Department followed.

Here, the First Department determined that the lower court properly rejected Honda and Nissan’s interstate federalism arguments. Per the First Department, although the defendants showed that New York’s interest in adjudicating the dispute may be outweighed by Florida’s interest, the defendants failed to establish that such interstate federalism concerns outweighed any other relevant considerations, such (1) the burden on defendants; (2) plaintiff’s interest in obtaining convenient and effective relief; (3) the interstate judicial system’s interest in obtaining the most efficient resolution of controversies; or (4) the shared interest of several states in furthering fundamental substantive social policies.

Thus, the First Department found that the defendants, who “purposefully availed themselves of the privilege of conducting activities in New York,” failed to present a compelling case that the presence of some other considerations rendered jurisdiction unreasonable. As such, the denial of summary judgment as to Honda and Nissan was upheld.

Read the full decision here.