Back in 2018, upon reading the bad general jurisdiction by
consent decision, Webb-Benjamin, LLC v. International Rug
Group, LLC, 192 A.3d 1133 (Pa. Super. 2018), and the worse
Hammons v. Ethicon, Inc., 190 A.3d 1248 (Pa.
Super. 2018), "specific" (we use that term advisedly)
jurisdiction case a few months later, we
commented that it appeared that the Commonwealth of
Pennsylvania was going off the personal jurisdiction "deep
end."
Following up on that metaphor, the Pennsylvania Supreme
Court's recent affirmance in Hammons v. Ethicon,
Inc., ___ A.3d ___, 2020 WL 6155256 (Pa. Oct. 21, 2020),
was the jurisprudential equivalent of yelling
"Cannonball!" while diving into the aforementioned
jurisdictional deep end. Hammons not only
concluded that the Supreme Court was all wet in
Bristol-Myers Squibb Co. v. Superior Court, 137 S.
Ct. 1773 (2017) ("BMS") (opting instead
for Justice Sotomayor's lone dissent), but also added yet
another burden to Pennsylvania's struggling
