Align Corporation, Ltd. v. BoustredAnnotate this Case
In 2012, Respondent Allister Boustred, a Colorado resident, purchased a replacement main rotor holder for his radio-controlled helicopter from a retailer in Fort Collins, Colorado. The main rotor holder was allegedly manufactured by Petitioner Align Corporation Limited (“Align”), a Taiwanese corporation, and distributed by Respondent Horizon Hobby, Inc. (“Horizon”), a Delaware-based corporation. Align had no physical presence in the United States, but it contracted with U.S.-based distributors to sell its products to retailers who, in turn, sell them to consumers. Boustred installed the main rotor holder to his helicopter and was injured in Colorado when the blades held by the main rotor holder released and struck him in the eye. He filed claims of strict liability and negligence against both Align and Horizon in Colorado. The issue this case presented for the Colorado Supreme Court's review centered on the stream of commerce doctrine and the prerequisites for a state to exercise specific personal jurisdiction over a non-resident defendant. The Colorado Supreme Court concluded that World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (1980), set out the controlling stream of commerce doctrine, which established that a forum state could assert jurisdiction where a plaintiff showed a defendant placed goods into the stream of commerce with the expectation that the goods will be purchased in the forum state. Applying this doctrine, the Court concluded Boustred made a sufficient showing to withstand a motion to dismiss.