Court Determines Germany Manufacturer May Be Liable in Massachusetts for Workplace Injury Case
In a recent federal appellate case, a man was badly injured while he was operating a machine at work in Lakeville, Massachusetts. Evidently, the man mistakenly hit the foot pedal on the machine, causing the machine to activate, crushing his left hand. The machine was manufactured by Schechtl Maschinenbau, a German company, and was sold to the man’s employer by MetalForming, Inc., an American company. The man sued Schechtl and MetalForming in Massachusetts. Schechtl argued that it could not be sued in Massachusetts because there was no personal jurisdiction.
The Concept of Personal Jurisdiction
Personal jurisdiction refers to a court’s ability to exercise power over the parties in a case. In order for personal jurisdiction to be established, a defendant must have certain “minimum contacts” with the state. To show sufficient contacts with the state under the applicable law, a plaintiff must show that: 1) the claims directly arise out of or relate to the defendant’s activities in the state; 2) the defendant’s contacts with the state constitute a purposeful availment of the privilege of doing business in the state; and 3) that jurisdiction is reasonable.
Personal Jurisdiction in the Case
In this case, the court decided that there were sufficient contacts to find personal jurisdiction. The court found that the claim was related to Schechtl’s contacts with the state, and that jurisdiction was reasonable. The main issue was whether Schechtl purposely availed itself of the privilege of doing business within the state. In finding that it purposely availed itself, the court considered whether the exercise of jurisdiction was foreseeable to the defendant.
The court explained that a defendant’s “regular course of sale” in the state could make jurisdiction foreseeable. It explained that jurisdiction might be foreseeable, for example, if a defendant designed a product for market in the state or advertised in the state. Here, Schechtl, through MetalForming, sold forty-five machines in Massachusetts over sixteen years, and provided over 200 parts to Massachusetts purchasers. In addition, in every sale, Schechtl manufactured the machines according to specifications provided by Massachusetts purchasers. Schechtl also provided materials to purchasers that instructed them to contact Schechtl directly for troubleshooting and replacement parts.
The court noted that this established a direct link between Schechtl and its purchasers, and that Schechtl deliberately created the link. The court explained that Schechtl sold products in the state over many years, and intitated an ongoing relationship with its purchasers. For these reasons, the court found the company had purposely availed itself of the privilege of doing business in the state, and that there was personal jurisdiction.
Contact a Massachusetts Injury Lawyer
If you have been injured, having an experienced Massachusetts personal injury advocate on your side is essential. The Neumann Law Group provides trustworthy legal representation to Massachusetts personal injury victims who have been injured in slip-and-fall accidents, on-the-job accidents, and motor vehicle collisions. We handle all types of personal injury claims and other general liability cases in Canton, Massachusetts, as well as in Michigan, California, and New York. Contact us at (800) 525-NEUMANN or fill out our online form to set up a free consultation.
See Related Posts:
Massachusetts Appeals Court Considers Definition of “Household Member” Under Insurance Policy, Massachusetts Injury Lawyer Blog, January 30, 2019.
Massachusetts Appeals Court Declines to Apply Exception to 30-Day Notice Requirement in Recent Slip-and-Fall Case, Massachusetts Injury Lawyer Blog, February 13, 2019.