As You Sow v. Crawford Laboratories, Inc.

As You Sow (AYS), a nonprofit organization, appeals the trial court’s order quashing service of summons over Crawford Laboratories, Inc. (Crawford) for lack of personal jurisdiction. Crawford shipped some of its products to a General Services Administration (G.S.A.) depot in Stockton, California pursuant to an out-of-state contract. G.S.A. determined the final destination of Crawford’s products but Crawford knew some products would remain in California. We must decide whether Crawford’s contacts with California were sufficient to provide the trial court with general jurisdiction. If too tenuous for general jurisdiction, were Crawford’s direct sales to private distributors in California on 16 separate occasions over a period of 6 years sufficient for limited jurisdiction?

We find Crawford’s contacts with California failed to provide the trial court with general jurisdiction but did furnish California with limited jurisdiction over Crawford so as not to offend the due process clause. Accordingly, we reverse.

Background

AYS, a nonprofit organization, investigates and sometimes prosecutes possible Proposition 65 (California’s Safe Drinking Water and Toxic Enforcement Act…