Gray v. American Radiator & Standard Sanitary Corp.
Supreme Court of Illinois
176 N.E.2d 761 (Ill. 1961)
Gray (plaintiff) was injured in Illinois by an exploding water heater whose safety valve, negligently manufactured by Titan (defendant), was sold to a Pennsylvania company that incorporated it into water heaters later sold nationally, including in Illinois; Titan itself had no offices, agents, or direct business dealings in Illinois. Gray sued Titan in Illinois under a long-arm statute reaching nonresidents who commit a tortious act in the state, and Titan moved to dismiss for lack of due process, arguing its only connection to Illinois was Gray's injury there; the trial court granted the motion.
Whether a corporation whose only contact with a state is selling a product for eventual use there has sufficient contacts to be held answerable in that state's courts for injuries caused by the product's defects.