Illinois Supreme Court Issues Supervisory Order On Personal Jurisdiction Appeal

On May 25, 2016, the Illinois Supreme Court issued a supervisory order requiring the Fifth District Appellate Court to take an appeal from Judge Stephen Stobbs’ recent denial of Ford Motor Company’s personal jurisdiction motion in Est. of Dale E. Jeffs (15 L 533), an asbestos case brought by Florida plaintiffs. Dale Jeffs worked as an insulator at various locations from 1968 to 1995, including at Ford’s plant in Michigan. Ford is incorporated in Delaware and its principal place of business is in Michigan.   

Under Daimler AG v. Bauman, 134 S. Ct. 746, 760 (2014), the appropriate analysis to determine whether or not a court has general personal jurisdiction over a corporate defendant rests on where that defendant has its primary place of business and in which state the defendant is incorporated. For an Illinois court to exercise general jurisdiction, due process requires that a defendant’s affiliations with Illinois be so constant and regular as to render [it] essentially at home in Illinois. Despite Daimler, Judge Stobbs denied Ford’s motion to dismiss and ruled that Ford’s contacts with Illinois are so substantial that it “has availed itself of the protection of the Illinois Courts and the benefits of Illinois law and by its own admission conducts substantial, not de minimus, business in Illinois.”