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

• A New Mexico resident died in a single-vehicle accident in Texas, driving a vehicle with a tire manufactured by Bridgestone that failed. The tire, installed as a spare by a New Mexico tire shop, was over twenty years old at the time of the accident. The plaintiffs, relatives of the deceased, filed a wrongful death suit against Bridgestone, alleging design and manufacturing defects in the tire and failure to notify about the tire's age-related risks. (paras 3-4)

Procedural History

• District Court of Santa Fe County, Francis J. Mathew, District Judge: Denied Bridgestone's motion to dismiss for lack of personal jurisdiction, finding specific jurisdiction was proper. (para 1)

Parties' Submissions

• Plaintiffs-Appellees: Argued that Bridgestone had purposely availed itself of the New Mexico market through various activities, including operating dealerships, maintaining an interactive website, offering awards, participating in litigation, and registering to do business in the state. They contended these actions gave rise to specific jurisdiction and that Bridgestone could anticipate being haled into court in New Mexico due to its defective product entering the stream of commerce. (para 6)
• Defendant-Appellant (Bridgestone): Contended that the district court lacked both general and specific jurisdiction over it, arguing it was not "at home" in New Mexico and the plaintiffs' claims did not arise from Bridgestone's conduct within the state. Bridgestone also argued that the issue of consent to jurisdiction by registration was beyond the scope of the question certified for interlocutory review or abandoned, and that Werner is no longer good law following Daimler AG v. Bauman. (paras 1, 5, 7)

Legal Issues

• Whether the district court had personal jurisdiction over Bridgestone, specifically if Bridgestone consented to general jurisdiction in New Mexico courts by registering in compliance with the Business Corporation Act. (para 1)
• Whether Werner v. Wal-Mart Stores, Inc. remains binding precedent for consent to jurisdiction through registration, despite the evolution of general jurisdiction jurisprudence. (para 2)

Disposition

• The Court of Appeals affirmed the district court’s denial of Bridgestone’s motion to dismiss for lack of jurisdiction, concluding that Bridgestone consented to general jurisdiction in New Mexico by registering to do business in the state. (para 13)

Reasons

• Per LINDA M. VANZI, Chief Judge (J. MILES HANISEE, Judge, and STEPHEN G. FRENCH, Judge Pro Tem concurring):
  The Court rejected Bridgestone's arguments against the applicability of Werner and consent to jurisdiction by registration, affirming the district court's decision but on the grounds of general rather than specific jurisdiction. It referenced the companion case Navarrete Rodriguez and prior decisions, including Pennsylvania Fire and Werner, to support that consent by registration under the Business Corporation Act constitutes consent to general jurisdiction. The Court also addressed and dismissed Bridgestone's dormant Commerce Clause argument, emphasizing New Mexico's interest in providing a forum for its residents. (paras 2, 8-12)