Product Liability

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7^th Circuit Court of Appeals

Case Name: B. D. v. Samsung SDI Co., Ltd.

Case No.: 23-1024

Officials: Sykes, Chief Judge, and Brennan and Lee, Circuit Judges.

Focus: Product Liability

The case stems from severe burns sustained by a minor, B.D., when a Samsung SDI battery exploded in his pocket in Indiana. B.D. filed a product liability lawsuit against Samsung SDI, a corporation organized under the laws of the Republic of Korea and having no physical presence in Indiana, in an Indiana state court. Samsung SDI moved the case to federal court and sought its dismissal on grounds of lacking personal jurisdiction. The district court rejected Samsung SDI’s motion, determining that specific personal jurisdiction existed over Samsung SDI in Indiana. Samsung SDI appealed.

The Seventh Circuit found that the district court’s record lacked sufficient facts to evaluate whether the stream-of-commerce theory’s requirements, which establish a defendant’s minimum contacts with a forum state, were met in this case. The court also distinguished the district court’s reliance on the Supreme Court case Ford Motor Co. v. Montana Eight Judicial District Court, noting that Samsung SDI did not advertise, sell, or service the specific batteries involved in Indiana. The court emphasized the unclear extent of Samsung SDI’s knowledge and expectations regarding the 18650 lithium ion batteries entering Indiana.

The court further observed that the record did not clearly establish whether Samsung SDI’s contacts with Indiana were connected to the alleged injury. Finally, the court concluded that additional facts were necessary to assess the fairness of exercising personal jurisdiction.

In light of these uncertainties, the court remanded the case for further jurisdictional discovery to collect more information about Samsung SDI’s connections with Indiana in relation to B.D.’s claimed injuries. The court specified that this remand exclusively addressed the issue of personal jurisdiction and did not compel the district court to reconsider any non-jurisdictional matters.

Remanded.

Decided 01/24/24

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