PERSONAL JURISDICTION – NO SPECIFIC PERSONAL JURISDICTION WHEN CASE DOES NOT RELATE TO DEFENDANT’S CONTACTS WITH FORUM STATE

In a recent California case, plaintiff purchased a battery from a vape shop and it exploded in his pants pocket.  The battery was manufactured by defendant, a South Korean company.  The vape shop did not sell defendant’s batteries and the battery it sold did not come in packaging. Defendant sold millions of batteries to three companies in California for use manufacturing electric vehicles.  This was not sufficient for general jurisdiction.  Therefore, plaintiff’s case did not arise out of defendant’s battery sales in California.  To exercise specific personal jurisdiction, the lawsuit must arise out of or relate to defendant’s contacts with the forum.  Therefore, appellate court reverses trial court’s denial of defendant’s motion to quash service of summons for lack of personal jurisdiction.  LG Chem, Ltd. v. Superior Court of San Diego County (2022)