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Totally Class-Less?: Examining Bristol-Myer's Applicability To Class Actions, Justin A. Stone

Fordham Law Review

In June 2017, the U.S. Supreme Court tightened the specific jurisdiction doctrine when it dismissed several plaintiffs’ claims in a mass tort action against pharmaceutical company Bristol-Myers Squibb (BMS) for lack of personal jurisdiction. The action was brought in a California state court and involved several hundred plaintiffs alleging that they were injured by Plavix, a drug BMS manufactures. The Supreme Court held that California could not constitutionally exercise personal jurisdiction over BMS as to the nonresident plaintiffs, who did not have an independent connection to California. While the nonresident plaintiffs argued that California had specific jurisdiction because their claims …