Judge: Daniel S. Murphy, Case: 24STCV32207, Date: 2025-03-14 Tentative Ruling

Case Number: 24STCV32207    Hearing Date: March 14, 2025    Dept: 32

BACKGROUND

            On December 6, 2024, Plaintiffs Eligio Morales Sanchez and Mayra Morales filed the instant action against various defendants arising from injuries sustained by Plaintiff Eligio Sanchez allegedly as a result of Defendants’ stone products.

            On February 14, 2025, Defendant Cambria Company LLC filed the instant motion to quash service of summons. Plaintiffs filed their opposition on March 3, 2025.

LEGAL STANDARD

“Due process permits the exercise of personal jurisdiction over a nonresident defendant in the following four situations: (1) where the defendant is domiciled in the forum state when the lawsuit is commenced; (2) where the defendant is personally served with process while he or she is physically present in the forum state; (3) where the defendant consents to jurisdiction; and (4) where the defendant has sufficient ‘minimum contacts’ with the forum state, such that the exercise of jurisdiction would not offend ‘traditional notions of fair play and substantial justice.’” (Muckle v. Superior Court (2002) 102 Cal.App.4th 218, 226.)

A defendant may establish sufficient minimum contacts with the forum state in one of two ways. For a court to exercise general jurisdiction, the defendant must have contact with the forum state that is substantial, continuous, and systematic. (Vons Companies, Inc. v. Seabest Foods, Inc. (1996) 14 Cal.4th 434, 445.) In such a case, the cause of action need not be related to the defendant’s contact with the forum state. (Id. at p. 446.) For a court to exercise specific jurisdiction, the following elements must be met: (1) the defendant has purposefully availed themselves of forum benefits; (2) the controversy is related to or arises out of the defendant’s contacts with the forum; and (3) the assertion of personal jurisdiction would comport with fair play and substantial justice. (Snowney v. Harrah’s Entertainment, Inc. (2005) 35 Cal.4th 1054, 1062.)

When personal jurisdiction is challenged by a nonresident defendant, the burden of proof is upon the plaintiff to demonstrate by a preponderance of the evidence that minimum contacts exist between the defendant and the forum state to justify imposition of personal jurisdiction. (Mihlon v. Sup. Ct. (1985) 169 Cal. App. 3d 703, 710.) Once facts showing minimum contacts with the forum state are established, the court must decide whether the exercise of jurisdiction would comport with fair play and substantial justice. (Vons, supra, 14 Cal. 4th at p. 447.)

DISCUSSION

I. General Jurisdiction

            “For a corporation, its domicile, place of incorporation, and principal place of business within a state constitute the paradigm bases for establishing general jurisdiction.” (Strasner v. Touchstone Wireless Repair & Logistics, LP (2016) 5 Cal.App.5th 215, 222.)

            There is no dispute that Defendant is a Minnesota company with its principal place of business in Minnesota. Plaintiff forgoes argument on general jurisdiction.

II. Specific Jurisdiction

            “Purposeful availment of forum benefits is only satisfied when the defendant purposefully and voluntarily directs his or her activities toward the forum so that he or she should expect, by virtue of the benefit he or she receives, to be subject to the court's jurisdiction based on his or her contacts with the forum.” (Moncrief v. Clark (2015) 238 Cal.App.4th 1000, 1006, internal citations omitted.)

            Defendant admits that it “manufactures quartz surface products at its facilities in California.” (Mtn. 4:7.) Defendant’s filings with the California Secretary of State show at least two office addresses in California. (Plntf.’s RJN, Ex. B-D.) Defendant’s website directs visitors to the California locations of its authorized dealers. (Metzger Decl., Ex. B.) Defendant also has a Cambria Sales and Distribution Center Showroom in Santa Fe Springs, California. (Ibid.)

This is sufficient to show that Defendant intentionally directed its activities toward California. In particular, Defendant specifically manufactures and sells its products in California. Plaintiffs’ claims arise from or are related to these contacts because the claims are based on injuries sustained by Plaintiff Eligio Sanchez during his work with Defendant’s stone products while in California.

Defendant argues that because Plaintiff Eligio Sanchez would not have come into contact with Defendant’s products but for his employment, “Plaintiffs must prove with admissible evidence that Cambria purposefully targeted Eligio Morales Sanchez’s California employers in the sale of its products which it manufactured in Minnesota.” (Mtn. 7:23-25.) However, Defendant admits that it “manufactures quartz surface products at its facilities in California.” (Mtn. 4:7.) The evidence also shows that Defendant has authorized dealers and showrooms in California. Defendant does not explain why Plaintiff must additionally prove that a product manufactured in Minnesota was directed at his employers in California. This is a heightened requirement not found in the law.     

The cited authority does not support Defendant’s position. The court in Bombardier Recreational Products, Inc. v. Dow Chemical Canada ULC (2013) 216 Cal.App.4th 591, 604 stated that “mere knowledge, without something more, is insufficient to establish jurisdiction in a forum state.” Rather, a defendant must have “intentionally brought goods into California.” (Ibid.) But this requirement is satisfied here because Defendant manufactures products in its plants in California and sells its products in California through authorized dealers and showrooms. Defendant was not merely aware that its products might be sold or used in California. Rather, Defendant specifically directed its sales to California for California users.

Defendant also cites to World-Wide Volkswagen Corp. (1980) 444 U.S. 286, 297 for the proposition that “presence of defendant’s product in forum state, even if foreseeable, is insufficient if the defendant did not direct it there.” (Mtn. 7:27-28.) However, Defendant did direct its products to California, as established above. Thus, it was not merely foreseeable that Defendant’s products would be sold and used in California.

Lastly, Defendant relies on Alber v. Owens (1967) 66 Cal.2d 790 to argue that Plaintiff’s employers had a nondelegable duty to provide a safe workplace. (Mtn. 7:28-8:2.) However, this is not pertinent to the question of personal jurisdiction. The fact that Plaintiff’s employers may also be liable does not alter the standard of personal jurisdiction applicable to Defendant. Alber does not discuss personal jurisdiction and is therefore inapplicable.  

Ultimately, the record supports the conclusion that Defendant has purposefully directed its activities toward California and that Plaintiffs’ claims arise out of or relate to these activities. Therefore, the Court may exercise personal jurisdiction over Defendant.

CONCLUSION

            Defendant Cambria Company LLC’s motion to quash service of summons is DENIED.