In Bandemer v. Ford Motor Company, the Minnesota Supreme Court recognized specific personal jurisdiction over Ford Motor Company because the “substantial connection between the defendant Ford, the forum Minnesota, and the claims brought . . . suffice[d] to establish specific personal jurisdiction over the company.” The court held that a Minnesota court had specific personal jurisdiction over Ford because of its targeted advertising, sales, and marketing in the state.
This Paper begins with a brief history of Minnesota’s approach to personal jurisdiction and the underlying justifications that led to the Bandemer decision. The facts and procedural history of Bandemer follow. The analysis of this Paper considers two opposing opinions. The first opinion argues that Bandemer,on its face, is consistent with International Shoe, as well as the evolution of personal jurisdiction analysis. Additionally, the decision in Bandemer supports the efficiency of the court. Next, the second opinion argues that the court erred in granting specific personal jurisdiction because Ford’s contacts with Minnesota were not targeted actions, but general conduct. This analysis focuses on the first three factors in Minnesota’s five-pronged test for satisfying federal due process.
This Paper was researched and written prior to the Supreme Court’s decision in Bandemer on March 25, 2021. As such, the Supreme Court’s decision and analysis are not considered in this Paper. However, the Supreme Court ultimately held that Ford was properly subject to specific personal jurisdiction in Minnesota and Montana.