Florian Hinrichs v. General Motors of Canada, Ltd.

Summary

The court affirmed dismissal of the claims against GM Canada because Alabama lacked both general and specific personal jurisdiction over the Canadian manufacturer. GM Canada was not essentially at home in Alabama, and the vehicle reached Alabama through the unilateral movement of its owner after being sold in Pennsylvania, creating no suit-related connection between GM Canada and Alabama. The court also held that GM Canada did not waive its jurisdictional defense because the waiver argument was not adequately preserved and, in any event, GM Canada did not cause unnecessary litigation of a potentially dispositive issue. Justice Murdock, dissenting, would have found specific jurisdiction, Justice Parker, dissenting, would have found waiver, and Justice Bolin concurred in the result while emphasizing uncertainty in specific-jurisdiction doctrine.