stream of commerce doctrine (California) · Go Syfert
← California issues

stream of commerce doctrine in California

6 California opinions name it 3 courts 1985–2019 0 in the last five years

The cases below were cited by California courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (6)

CaseFollowedCited
World-Wide Volkswagen Corp. v. Woodsongreen
scotus · 1980 · cited in 2 California opinions naming this issue, 1985–2002
2 sentences

1985(See World-Wide Volkswagen, supra, 444 U.S. at p. 298 [ 62 L.Ed.2d at p. 502 ]; Nelson, supra, 717 F.2d at p. 1126; Gray, supra, 176 N.E.2d at p. 766 .) Therefore, the stream of commerce rule announced in World-Wide Volkswagen provides a possible basis for jurisdiction.

1985(See World-Wide Volkswagen, supra, 444 U.S. at p. 298 [ 62 L.Ed.2d at p. 502 ]; Nelson, supra, 717 F.2d at p. 1126; Gray, supra, 176 N.E.2d at p. 766 .) Therefore, the stream of commerce rule announced in World-Wide Volkswagen provides a possible basis for jurisdiction.

22
Bridgestone Corp. v. Superior Courtgreen
calctapp · 2002 · cited in 2 California opinions naming this issue, 2005–2005
2 sentences

2005(See Bridgestone, supra, 99 Cal.App.4th at p. 777 , 121 Cal. Rptr.2d 673 [tire sales]; see also § 452, subds. (g), (h).) Thus, we are satisfied that the plaintiffs met their burden of proof of the first, purposeful availment prong of the stream of commerce test. 3.

2005(See Bridgestone, supra, 99 Cal.App.4th at p. 777 [tire sales]; see also § 452, subds. (g), (h).) Thus, we are satisfied that plaintiffs met their burden of proof of the first, purposeful availment prong of the stream of commerce test. 3.

12
St. Joe Paper Co. v. Superior Courtgreen
calctapp · 1981 · cited in 1 California opinions naming this issue, 2002–2002
2 sentences

2002Joe Paper Co. v. Superior Court (1981) 120 Cal.App.3d 991, 999-1000 [ 175 Cal.Rptr. 94 ]; Sanders v. CEG Corp. (1979) 95 Cal.App.3d 779, 785-786 [ 157 Cal.Rptr. 252 ].) In As You Sow, the court held that a manufacturer whose only contacts with California were through a series of sales to California distributors was subject to personal jurisdiction because the sales to California distributors reflected an effort to benefit from the California market and constituted economic activity within California “ ‘ “as a matter of commercial actuality.” ’ [Citation.]” (As You Sow, at pp. 1864-1865, 1871.)

2002Joe Paper Co. v. Superior Court (1981) 120 Cal.App.3d 991, 999-1000 [ 175 Cal.Rptr. 94 ]; Sanders v. CEG Corp. (1979) 95 Cal.App.3d 779, 785-786 [ 157 Cal.Rptr. 252 ].) In As You Sow, the court held that a manufacturer whose only contacts with California were through a series of sales to California distributors was subject to personal jurisdiction because the sales to California distributors reflected an effort to benefit from the California market and constituted economic activity within California “ ‘ “as a matter of commercial actuality.” ’ [Citation.]” (As You Sow, at pp. 1864-1865, 1871.)

11
Felix v. Bomoro Kommanditgesellschaftgreen
calctapp · 1987 · cited in 1 California opinions naming this issue, 2002–2002
2 sentences

2002(But see Felix v. Bomoro Kommanditgesellschaft (1987) 196 Cal.App.3d 106, 114-117 [ 241 Cal.Rptr. 670 , 69 A.L.R.4th 1 ].) We conclude that a manufacturer’s placement of goods in the stream of commerce with the expectation that they will be purchased or used by consumers in California indicates an intention to serve the California market “directly or indirectly” (World-Wide Volkswagen Corp. v. Woodson, supra, 444 U.S. at p. 297 [ 100 S.Ct. at p. 567 ]) and constitutes purposeful availment if the income earned by the manufacturer from sale or use of its product in California is substantial.

2002(But see Felix v. Bomoro Kommanditgesellschaft (1987) 196 Cal.App.3d 106, 114-117 [ 241 Cal.Rptr. 670 , 69 A.L.R.4th 1 ].) We conclude that a manufacturer’s placement of goods in the stream of commerce with the expectation that they will be purchased or used by consumers in California indicates an intention to serve the California market “directly or indirectly” (World-Wide Volkswagen Corp. v. Woodson, supra, 444 U.S. at p. 297 [ 100 S.Ct. at p. 567 ]) and constitutes purposeful availment if the income earned by the manufacturer from sale or use of its product in California is substantial.

11
Sanders v. CEG CORP.green
calctapp · 1979 · cited in 1 California opinions naming this issue, 2002–2002
2 sentences

2002Joe Paper Co. v. Superior Court (1981) 120 Cal.App.3d 991, 999-1000 [ 175 Cal.Rptr. 94 ]; Sanders v. CEG Corp. (1979) 95 Cal.App.3d 779, 785-786 [ 157 Cal.Rptr. 252 ].) In As You Sow, the court held that a manufacturer whose only contacts with California were through a series of sales to California distributors was subject to personal jurisdiction because the sales to California distributors reflected an effort to benefit from the California market and constituted economic activity within California “ ‘ “as a matter of commercial actuality.” ’ [Citation.]” (As You Sow, at pp. 1864-1865, 1871.)

2002Joe Paper Co. v. Superior Court (1981) 120 Cal.App.3d 991, 999-1000 [ 175 Cal.Rptr. 94 ]; Sanders v. CEG Corp. (1979) 95 Cal.App.3d 779, 785-786 [ 157 Cal.Rptr. 252 ].) In As You Sow, the court held that a manufacturer whose only contacts with California were through a series of sales to California distributors was subject to personal jurisdiction because the sales to California distributors reflected an effort to benefit from the California market and constituted economic activity within California “ ‘ “as a matter of commercial actuality.” ’ [Citation.]” (As You Sow, at pp. 1864-1865, 1871.)

11
Nelson v. Park Industriesgreen
ca7 · 1983 · cited in 1 California opinions naming this issue, 1985–1985
2 sentences

1985(See World-Wide Volkswagen, supra, 444 U.S. at p. 298 [ 62 L.Ed.2d at p. 502 ]; Nelson, supra, 717 F.2d at p. 1126; Gray, supra, 176 N.E.2d at p. 766 .) Therefore, the stream of commerce rule announced in World-Wide Volkswagen provides a possible *48 basis for jurisdiction.

1985(See World-Wide Volkswagen, supra, 444 U.S. at p. 298 [ 62 L.Ed.2d at p. 502 ]; Nelson, supra, 717 F.2d at p. 1126; Gray, supra, 176 N.E.2d at p. 766 .) Therefore, the stream of commerce rule announced in World-Wide Volkswagen provides a possible basis for jurisdiction.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in California. Read the followed side critically anyway.

Also cited on this issue (9)

CaseCitedYears
Vandermark v. Ford Motor Co. green
cal · 1964
2 sentences

2019Unless we reconcile the tension between these two lines of authority in this way, who knows what unintended confusion we could be sowing in an area of law where predictability and certainty are as important as they are in bankruptcy. 16 Accordingly, because there is no proof in the summary judgment record bearing on what the scope of the "free and clear order" for the ANC-Cerberus asset sale was, or whether notice satisfying the rule in Elliott was given, I would conclude that Stewart does not apply, even assuming there were no triable issue on express assumption. *221 * * * * * * * This case

2019Unless we reconcile the tension between these two lines of authority in this way, who knows what unintended confusion we could be sowing in an area of law where predictability and certainty are as important as they are in bankruptcy. 16 Accordingly, because there is no proof in the summary judgment record bearing on what the scope of the "free and clear order" for the ANC-Cerberus asset sale was, or whether notice satisfying the rule in Elliott was given, I would conclude that Stewart does not apply, even assuming there were no triable issue on express assumption. *221 * * * * * * * This case

22019–2019
Greenman v. Yuba Power Products, Inc. green
cal · 1963
2 sentences

2019Unless we reconcile the tension between these two lines of authority in this way, who knows what unintended confusion we could be sowing in an area of law where predictability and certainty are as important as they are in bankruptcy. 16 Accordingly, because there is no proof in the summary judgment record bearing on what the scope of the "free and clear order" for the ANC-Cerberus asset sale was, or whether notice satisfying the rule in Elliott was given, I would conclude that Stewart does not apply, even assuming there were no triable issue on express assumption. *221 * * * * * * * This case

2019Unless we reconcile the tension between these two lines of authority in this way, who knows what unintended confusion we could be sowing in an area of law where predictability and certainty are as important as they are in bankruptcy. 16 Accordingly, because there is no proof in the summary judgment record bearing on what the scope of the "free and clear order" for the ANC-Cerberus asset sale was, or whether notice satisfying the rule in Elliott was given, I would conclude that Stewart does not apply, even assuming there were no triable issue on express assumption. *221 * * * * * * * This case

22019–2019
Ray v. Alad Corp. green
cal · 1977
2 sentences

2019Unless we reconcile the tension between these two lines of authority in this way, who knows what unintended confusion we could be sowing in an area of law where predictability and certainty are as important as they are in bankruptcy. 16 Accordingly, because there is no proof in the summary judgment record bearing on what the scope of the "free and clear order" for the ANC-Cerberus asset sale was, or whether notice satisfying the rule in Elliott was given, I would conclude that Stewart does not apply, even assuming there were no triable issue on express assumption. *221 * * * * * * * This case

2019Unless we reconcile the tension between these two lines of authority in this way, who knows what unintended confusion we could be sowing in an area of law where predictability and certainty are as important as they are in bankruptcy. 16 Accordingly, because there is no proof in the summary judgment record bearing on what the scope of the "free and clear order" for the ANC-Cerberus asset sale was, or whether notice satisfying the rule in Elliott was given, I would conclude that Stewart does not apply, even assuming there were no triable issue on express assumption. *221 * * * * * * * This case

22019–2019
Snowney v. Harrah's Entertainment, Inc. green
cal · 2005
1 sentence

2005(Snowney, supra, 35 Cal.4th at p. 1062 ; see Burger King, supra, 471 U.S. at pp. 472-473; Helicopteros Nacionales de Colombia v. Hall, supra, 466 U.S. at p. 414 ; Vons, supra, 14 Cal.4th at pp. 446-447; F. Hoffman-La Roche, supra, 130 Cal.App.4th at p. 796 ; Bridgestone, supra, 99 Cal.App.4th at pp. 773-774.) Three distinct theories of specific jurisdiction are at issue in this appeal—the stream of commerce doctrine, the effects test, and the commission of acts in California in furtherance of a conspiracy.

12005–2005
F. HOFFMAN-LA ROCHE, LTD. v. Superior Court green
calctapp · 2005
1 sentence

2005(Snowney, supra, 35 Cal.4th at p. 1062 ; see Burger King, supra, 471 U.S. at pp. 472-473; Helicopteros Nacionales de Colombia v. Hall, supra, 466 U.S. at p. 414 ; Vons, supra, 14 Cal.4th at pp. 446-447; F. Hoffman-La Roche, supra, 130 Cal.App.4th at p. 796 ; Bridgestone, supra, 99 Cal.App.4th at pp. 773-774.) Three distinct theories of specific jurisdiction are at issue in this appeal—the stream of commerce doctrine, the effects test, and the commission of acts in California in furtherance of a conspiracy.

12005–2005
Helicopteros Nacionales De Colombia, S. A. v. Hall green
scotus · 1984
1 sentence

2005(Snowney, supra, 35 Cal.4th at p. 1062 ; see Burger King, supra, 471 U.S. at pp. 472-473; Helicopteros Nacionales de Colombia v. Hall, supra, 466 U.S. at p. 414 ; Vons, supra, 14 Cal.4th at pp. 446-447; F. Hoffman-La Roche, supra, 130 Cal.App.4th at p. 796 ; Bridgestone, supra, 99 Cal.App.4th at pp. 773-774.) Three distinct theories of specific jurisdiction are at issue in this appeal—the stream of commerce doctrine, the effects test, and the commission of acts in California in furtherance of a conspiracy.

12005–2005
Secrest MacHine Corp. v. Superior Court green
cal · 1983
1 sentence

2002Thus, Asahi did not overrule prior United States Supreme Court opinions articulating the stream of commerce doctrine and did not affect California’s “commercial actuality” standard expressed in Secrest Machine Corp. v. Superior Court, supra, 33 Cal.3d 664 .

12002–2002
Asahi Metal Industry Co. v. Superior Court of Cal., Solano Cty. green
scotus · 1987
2 sentences

2002Joe Paper Co. v. Superior Court (1981) 120 Cal.App.3d 991, 999-1000 [ 175 Cal.Rptr. 94 ]; Sanders v. CEG Corp. (1979) 95 Cal.App.3d 779, 785-786 [ 157 Cal.Rptr. 252 ].) In As You Sow, the court held that a manufacturer whose only contacts with California were through a series of sales to California distributors was subject to personal jurisdiction because the sales to California distributors reflected an effort to benefit from the California market and constituted economic activity within California “ ‘ “as a matter of commercial actuality.” ’ [Citation.]” (As You Sow, at pp. 1864-1865, 1871.)

2002Joe Paper Co. v. Superior Court (1981) 120 Cal.App.3d 991, 999-1000 [ 175 Cal.Rptr. 94 ]; Sanders v. CEG Corp. (1979) 95 Cal.App.3d 779, 785-786 [ 157 Cal.Rptr. 252 ].) In As You Sow, the court held that a manufacturer whose only contacts with California were through a series of sales to California distributors was subject to personal jurisdiction because the sales to California distributors reflected an effort to benefit from the California market and constituted economic activity within California “ ‘ “as a matter of commercial actuality.” ’ [Citation.]” (As You Sow, at pp. 1864-1865, 1871.)

12002–2002
Gray v. American Radiator & Standard Sanitary Corp. green
ill · 1961
2 sentences

1985(See World-Wide Volkswagen, supra, 444 U.S. at p. 298 [ 62 L.Ed.2d at p. 502 ]; Nelson, supra, 717 F.2d at p. 1126; Gray, supra, 176 N.E.2d at p. 766 .) Therefore, the stream of commerce rule announced in World-Wide Volkswagen provides a possible *48 basis for jurisdiction.

1985(See World-Wide Volkswagen, supra, 444 U.S. at p. 298 [ 62 L.Ed.2d at p. 502 ]; Nelson, supra, 717 F.2d at p. 1126; Gray, supra, 176 N.E.2d at p. 766 .) Therefore, the stream of commerce rule announced in World-Wide Volkswagen provides a possible basis for jurisdiction.

11985–1985

Where else courts name it

TX 37 (1985–2025) AL 12 (2002–2016) CA 6 (1985–2019) NM 5 (2012–2025) IL 4 (2013–2016) GA 3 (1992–2022) WA 3 (2015–2017) WI 3 (1994–2016) UT 3 (1992–2019) CO 3 (2016–2017) NJ 2 (1988–2010) OK 2 (2018–2018) TN 2 (1992–2013) IA 2 (2015–2015) DE 2 (1997–2019)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

← Caselaw search · G Cite Topics · Brief Check