Supreme Court of Alabama

Ex Parte Edgetech I.g., Inc., N/k/a Quanex I.g. Systems, Inc. (in Re Tiffin Motorhomes, Inc. v. Thompson I.g., LLC…

July 25, 2014159 So. 3d 629

Summary

The court granted Edgetech's petition for a writ of mandamus and directed the trial court to dismiss the claims against Edgetech for lack of personal jurisdiction. Edgetech's minimal Alabama sales were insufficient for general jurisdiction, and the record did not show that Edgetech purposefully directed its conduct toward Alabama or reasonably anticipated being sued there for purposes of specific jurisdiction. The court also declined to overrule Alabama's existing specific-jurisdiction test based on the intervening United States Supreme Court decision because that decision did not clearly reject the governing stream-of-commerce framework.