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Olivia Clayton | Revisiting Bristol-Myers Squibb’s Applicability in Collective Lawsuits
In 2017, the Supreme Court in Bristol-Myers Squibb Co. v. Superior Court of California addressed the issue of specific jurisdiction in class action lawsuits. 582 U.S. 255 (2017). The case involved over 600 plaintiffs, including residents and nonresidents of California, who joined a lawsuit alleging product defects in a medication manufactured by Bristol-Myers Squibb (BMS). In response, BMS filed a motion to dismiss the nonresident plaintiffs’ claims for lack of personal jurisdiction. The Court agreed, holding that because the claims would remain the same with the exclusion of the nonresident plaintiffs, there was no basis for asserting specific jurisdiction over them. This decision reinforced the standard established in International Shoe Co. v. Washington that a defendant must have sufficient minimum contacts with the forum state for the court to assert personal jurisdiction. 326 U.S. 310 (1945).