Mazda Motor Corp. v. Triche

In a products liability/wrongful death suit over a Mazda3 that caught fire after a rear-end collision in Florida, the Third DCA affirmed denial of Mazda Japan's motion to dismiss for lack of personal jurisdiction. Applying Ford Motor Co. v. Montana Eighth Judicial District Court and Asahi's 'additional conduct' factors, the majority held Mazda Japan purposefully availed itself of the Florida market by designing vehicles for the U.S. market, registering U.S. trademarks, admitting its vehicles were 'intended for the United States market, including Florida,' shipping vehicles to Florida ports, ordering recalls naming Florida, and marketing through its wholly owned U.S. distributor subsidiary. Judge Lobree dissented, arguing the record showed no targeting of Florida by the Japanese parent under the 'stream of commerce plus' test.

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