Federal District Court Rejects "Nicastro Holding"

In Leja v. Schmidt Mfg., Inc., No. 01-5042 (DRD), 2010 U.S. Dist. LEXIS 110907 (D.N.J. Oct. 19, 2010), a federal district court in New Jersey declined to follow the decision of the New Jersey Supreme Court in Nicastro v. McIntyre Mach. Am., Ltd., 201 N.J. 48, 987 A.2d 575 (2010), concluding that, to the extent that the Nicastro holding expanded personal jurisdiction beyond the bounds set by the United States Supreme Court, it had to be disregarded. 2010 U.S. Dist. LEXIS 110907, at *1. In Nicastro, decided earlier this year, the New Jersey Supreme Court held that "a foreign manufacturer that places a defective product in the stream of commerce through a distribution scheme that targets a national market, which includes New Jersey, may be subject to the in personam jurisdiction of a New Jersey court in a product-liability action." Nicastro 201 N.J. at 73, 987 A.2d at 589.