LG Chem, Ltd. v. Superior CourtAnnotate this Case
Ryan Lawhon alleged he was severely injured when an 18650 lithium-ion battery he bought from a San Diego vape shop suddenly exploded in his pants pocket. In addition to the vape shop and vape distributor, he sued LG Chem Ltd. (LG Chem), the South Korean manufacturer of lithium-ion batteries for negligence and product liability. The trial court denied LG Chem’s motion to quash service of summons for lack of personal jurisdiction, finding the court’s exercise of specific jurisdiction over LG Chem comported with federal due process. LG Chem petitioned the California Court of Appeal for a writ of mandate directing the trial court to vacate its order denying the motion to quash. The Court issued the writ: LG Chem sold 18650 batteries as industrial component products to original equipment manufacturers and battery packers who sell to original equipment manufacturers. It did not design, manufacture, distribute, advertise or sell the batteries for sale to or use by individual consumers as standalone, replaceable batteries. It had no connection to the vape shop or the vape distributor responsible for selling the defective battery that injured Lawhon. Its activities in California consisted of sales of 18650 batteries to three California companies in the electric vehicle industry for use in electric vehicles. The question presented was whether Lawhon’s personal injury claims arose from or related to those sales, to which the Court concluded they did not. Thus, the Court granted the petition and directed the trial court to vacate its order denying the motion to quash, and to enter a new order granting the motion.