Document Type

Article

Publication Date

2024

Abstract

This Article provides a doctrinal mapping of the Supreme Court’s modern personal jurisdiction jurisprudence through the lens of Ford Motor Co. v. Montana Eighth Judicial District Court. Tracing the evolution of specific and general jurisdiction from International Shoe through Bristol-Myers Squibb, the Article examines how the Court’s articulation of the “arise out of or relate to” requirement has shifted over time. While Ford purported to clarify the relationship prong of specific jurisdiction, the Article argues that the decision instead destabilizes the doctrinal boundary between specific and general jurisdiction. By reinvigorating the “relate to” language without articulating clear limiting principles, the Court risks expanding specific jurisdiction in ways that resemble the broader sweep historically associated with general jurisdiction. The Article contends that this doctrinal blurring creates analytical confusion, undermines predictability for litigants, and invites renewed litigation over the scope of constitutional due process constraints on state court authority.

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