BOISE, Idaho (Legal Newsline) - A chef who was seriously injured when a wine bottle shattered as she was opening it can proceed with a lawsuit against the Italian manufacturer of the vessel, after the Idaho Supreme Court ruled a lower court applied too strict a test for whether it had jurisdiction over the foreign company.
Ruling for the first time on the specific question of how to apply U.S. Supreme Court precedent on specific personal jurisdiction, the state high court said Idaho law requires the broadest interpretation of a decades-old test focused on whether companies released their products into the “stream of commerce” leading to the state.
The court rejected a narrower “stream of commerce plus” doctrine, requiring more substantial contacts with the state, which has never garnered a majority vote by Supreme Court justices. The Idaho Supreme Court upheld the dismissal of claims against Antinori and Chateau St. Michelle, saying there was insufficient evidence to show they caused the defect that led the bottle to shatter.
Mary Clare Griffin was opening a bottle of 2011 Villa Antinori Chiantic Classico to make tomato sauce in 2017 when the neck snapped and the bottle shattered, severely injuring her hand. She sued the winemaker Antinori; the distributor, Chateau St. Michelle; retailer Albertson’s and Zignagno, the Italian manufacturer of the bottle.
Zignagno fought personal jurisdiction, arguing it had no commercial presence in Idaho other than selling bottles to Antinori in Italy that wound up on store shelves in the state. Under a string of Supreme Court decisions, companies can be subject to personal jurisdiction only if they have substantial and continuous contacts with a state, such as owning real estate or operating sales offices there, or if they sell products with the knowledge and expectation they will be sold there. In two of those decisions, a plurality of justices have suggested a foreign company’s contacts must have a “plus” factor, such as negotiations with in-state companies, contracts specific to the state, or advertising aimed specifically at the state.
The trial court dismissed claims against most of the defendants after a plaintiff expert attributed the bottle’s failure to a “Hertzian Conoid,” or cone-shaped fracture that could have occurred in the factory or somewhere else along the chain of distribution including when the bottle was stocked on the retail shelf at Albertson’s. The court also refused to exercise jurisdiction over Zignagno, citing “stream of commerce plus.”
The Idaho Supreme Court reversed on personal jurisdiction in a July 19 decision, ruling that the trial judge had pushed state law too far. Idaho uses “narrowest grounds analysis” to interpret fragmented Supreme Court decisions, the state supreme court explained, applying only the reasoning of justices who agreed with the result on the narrowest grounds.
The trial judge cited a previous state Supreme Court decision in favor of two Pennsylvania companies that had owned a helicopter that ended up in Idaho, saying they couldn’t be subject to personal jurisdiction merely because of “fortuitous circumstance.” But Zignago sold 92 million bottles to Antinori alone over a 10-year period and 43 million of them ended up in the U.S., the Idaho Supreme Court noted.
“What the record shows that Zignago did do was place millions of its bottles in the United States by selling them to a manufacturer it reasonably knew exported those bottles throughout the United States through a network of exporters, distributors, and retailers,” the court said. “Given the extensive network into which Zignago sent its bottles, it cannot credibly maintain it was unforeseeable that its bottles would end up in the hands of a chef in Idaho.”
It would be a burden for Zignagno to go to Idaho “to defend one of the 92 million bottles it produced,” the court acknowledged. But that’s the price to pay for selling products in the state, the court said, as balanced against the rights of Idaho citizens to obtain relief in the courts.
“Griffin did not travel to Italy to purchase the bottle and bring it back to Idaho; rather, the bottle was shipped, sold, and caused damage in Idaho,” the court concluded. “Therefore, it would place an unreasonable burden to force Griffin to venture to Italy to seek redress.”