A terrible New Mexico car accident occurred when a tire tread peeled off the right rear tire of a 1993 Ford E-350 Super Club Wagon traveling on U.S. Highway 54 in Guadalupe County, New Mexico. The vehicle, which was en route from Mexico to Colorado, left the road and rolled over three times. Two of the occupants of the vehicle were ejected and died, another occupant was rendered quadriplegic and died from the injuries he sustained in the accident, and several other people who were in the car at the time of the accident also sustained injuries.A lawsuit was filed against the car manufacturer, the tire manufacturer, and the person who installed the tire on the vehicle in the names of some of the individuals involved in the accident, and through representatives with respect to the other people involved in the accident. The plaintiffs were all Mexican nationals. The defendants, also not residents of New Mexico, each moved to dismiss, asserting that there was not personal jurisdiction over the defendants. The District Court of Santa Fe County, New Mexico conducted a hearing, following which it denied dismissal of the lawsuit. The defendants then filed applications for interlocutory appeal, which were granted by the Court of Appeals of New Mexico.
On appeal, the Court analyzed whether the defendants had minimum contacts with New Mexico that supported the exercise of specific jurisdiction. The Court applied the standards of a precedent in which the Court had held that New Mexico courts could properly exercise jurisdiction over a Chinese corporate defendant that manufactured bicycle parts after it placed the allegedly defective parts on the market with the intention that they be distributed and sold in the United States, including in New Mexico.
The Court looked at the defendants’ contacts with New Mexico, which were presented in the form of evidence submitted by the plaintiffs. The contacts included extensive contacts by the car manufacturer defendant, including having dealerships in the state, engaging in marketing in the state, and maintaining a website allowing prospective customers to obtain a quote on a vehicle and search an inventory of vehicles in stock in the state. Similarly, the evidence that the plaintiffs presented with respect to the tire manufacturer showed that this defendant has dealers in New Mexico, sends personnel to the state to assess the performance of its tires, and maintains a website targeting people who live in New Mexico. The Court observed that the claims at issue did not need to be causally related to the defendants’ conduct in the forum state but instead needed only to “lie in the wake” of the defendants’ activities in the forum state. The Court affirmed the ruling below, denying the defendants’ motion to dismiss.