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.
Key facts
- Plaintiff Triche, a Florida resident, was injured in a rear-end collision involving a Mazda3 that caught fire; Triche sued Mazda Motor Corp. (the Japanese parent manufacturer) and others in a products liability and wrongful death action in Florida.
- The trial court denied Mazda Japan's motion to dismiss for lack of personal jurisdiction over the foreign defendant.
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Why it matters
This is a significant Florida appellate application of Ford Motor Co. to foreign parent manufacturers who insulate themselves behind U.S. distribution subsidiaries, and it arguably narrows the reach of the Third DCA's… — full analysis with a trial
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