Rush v. Savchuk

Facts of the Case

Plaintiff claimant was riding in a car operated by defendant insured and was injured in a car accident in Indiana. Plaintiff, a Minnesota resident, brought an action for negligence in a Minnesota state court against defendant, an Indiana resident. Since defendant had no contacts with Minnesota that would support in personam jurisdiction, plaintiff sought to obtain quasi in rem jurisdiction by garnishing the contractual obligation of defendant’s insurer licensed to do business in Minnesota. The trial court held in plaintiff’s favor. The Supreme Court of Minnesota affirmed the trial court’s judgment. The Supreme Court of the United States reversed the state supreme court’s decision.

Question

Can a state have jurisdiction over a defendant with no connections in the state by attaching the contractual obligation of an insurer licensed in the state?

CONCLUSION

No. Justice Thurgood Marshall delivered the opinion of the 7-2 majority. The Court held that there must be a certain amount of minimum contacts between the defendant and the state in which the suit occurs. The fact that Rush’s insurance company does business in Minnesota is not a sufficient link between him and the state, especially since he owns no property there and has no other connection. Rush had no reason to suspect that having an insurance contract with State Farm would subject him to the possibility of a lawsuit in all states where State Farm does business.Justice John Paul Stevens wrote a dissenting opinion and argued that the insurance company could be sued in Minnesota under Rush’s policy. As long as it is understood that the Minnesota court has jurisdiction over the policy and State Farm, rather than the defendant, Justice Stevens argued that the suit could be continued.

Case Information

  • Citation: 444 US 320 (1980)
  • Argued: Oct 3, 1979
  • Decided Jan 21, 1980