Bristol-Myers Squibb Co. v. Superior Court of Cal., San Francisco Cty.
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
The 3 confirmed limits are listed below; many other citing opinions instead describe how Bristol-Myers Squibb affected earlier jurisdiction cases.
35 later cases cite Bristol-Myers Squibb Co. v. Superior Court of Cal., San Francisco Cty.; 35 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.
Relying on Bristol-Myers Squibb Co. v. Superior Court of Cal., San Francisco Cty.?
This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.
Treatments
Limited
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A federal district court held that Bristol-Myers Squibb does not govern the claims of unnamed members of a federal class action.
Knotts v. Nissan North America, Inc. · District of Minnesota · filed
Defendant relies upon the Supreme Court’s decision in Bristol-Myers Squibb Co. v. Superior Court of California, San Francisco Cty., 137 S. Ct. 1773 (2017) (“BMS”). ... The Court agrees with this broader set of cases and holds that BMS is inapplicable to unnamed parties in a federal class action suit.
Read the full opinion on CourtListener → -
A federal district court held that Bristol-Myers Squibb does not displace pendent personal jurisdiction over a related claim against a defendant already before the court.
Parimal v. Manitex International, Inc. · District of Connecticut · filed
But Bristol-Myers Squibb is distinguishable from the facts here because that case dealt with the propriety of exercising personal jurisdiction over out-of-state plaintiffs who had no case-related connection to the forum state, not, as here, an out-of-state defendant over whom the court already has personal jurisdiction with respect to at least one claim.
Read the full opinion on CourtListener → -
A federal district court declined to apply Bristol-Myers Squibb to unnamed members of a nationwide class action.
Hines v. Equifax Information Services LLC · Eastern District of New York · filed
Contrary to Equifax’s arguments, the Supreme Court’s decision in Bristol-Myers Squibb Co. v. Superior Court of California, 582 U.S. 255 (2017), does not call into question this predominant approach to personal jurisdiction in class actions. Bristol-Myers Squibb was not a class action, and so the Supreme Court had no occasion in that case to consider whether unnamed class members should be treated as parties for purposes of personal-jurisdiction analysis.
Read the full opinion on CourtListener →
Does this case still carry your argument?
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