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

• The plaintiff, as personal representative for the deceased's estate, filed a wrongful death action against Ford, alleging that the roof structure of a 2000 Ford F-250 was defectively designed, leading to the deceased's death in a rollover accident on New Mexico State Road 206. The vehicle was purchased from a private seller in New Mexico. The plaintiff claimed jurisdiction over Ford based on its business activities within the state (paras 3-4).

Procedural History

• District Court of Santa Fe County: Found specific personal jurisdiction but not general personal jurisdiction over Ford, denying Ford's motion to dismiss for lack of personal jurisdiction (para 2).

Parties' Submissions

• Plaintiff: Argued that the district court had specific personal jurisdiction due to Ford's substantial contacts with New Mexico and its placement of the F-250 into the stream of commerce, anticipating being haled into court in New Mexico (para 5).
• Ford: Contended that the district court lacked specific personal jurisdiction as the plaintiff's claims did not arise from any in-state activities, and argued against general jurisdiction by stating Ford was not incorporated in New Mexico nor had its principal place of business there (para 4).

Legal Issues

• Whether Ford consented to general personal jurisdiction in New Mexico courts by registering to do business in the state (para 1).
• Whether the district court had specific personal jurisdiction over Ford.

Disposition

• The Court of Appeals affirmed the denial of Ford's motion to dismiss, concluding that Ford consented to general jurisdiction in New Mexico by registering to do business in the state, thus not reaching the issue of specific jurisdiction (para 2).

Reasons

• The Court of Appeals, led by Chief Judge Linda M. Vanzi, with Judges J. Miles Hanisee and Stephen G. French concurring, based its decision on the interpretation of the United States Supreme Court’s decision in Pennsylvania Fire Insurance Co. of Philadelphia v. Gold Issue Mining & Milling Co. and the Court’s decision in Werner v. Wal-Mart Stores, Inc. The court concluded that both decisions remain binding and that Ford, by registering to do business in New Mexico, consented to general jurisdiction in New Mexico courts. The court distinguished its decision from the implications of the Supreme Court's decisions in International Shoe Co. v. Washington and Daimler AG v. Bauman, noting that neither explicitly overruled Pennsylvania Fire’s holding regarding consent by registration. The court also addressed and rejected Ford's arguments that consent by registration violates the unconstitutional conditions doctrine or the dormant Commerce Clause, concluding that New Mexico has a substantial interest in adjudicating suits involving its residents or injuries occurring within the state (paras 7-32).