Once upon a time, the California Supreme Court was at the
forefront of expanding tort liability. About 30 years ago, things
shifted and the court became substantially more balanced, if not
defense-oriented. That trend has ended. If those who forget history
are doomed to repeat it, then that is the situation in California
today because the boundaries of personal jurisdiction and tort
liability have once again been expanded.
As most lawyers learned in the first weeks of law school, a
court cannot exercise jurisdiction over a non-resident defendant
unless the defendant has sufficient contacts with the state either
generally or in connection with the particular claims being
litigated. In Bristol-Myers Squibb Co. v. Superior Court
(No. S221038, 8/29/2016), the California Supreme Court expanded the
borders of specific jurisdiction, holding the California courts
could exercise jurisdiction over a non-resident defendant for
claims made by non-resident plaintiffs involving
