In recent years, the U.S. Supreme Court has repeatedly clarified the limits on states’ personal jurisdiction over foreign corporations. Some would say it has repeatedly restricted personal jurisdiction. Indeed, by now a pattern has emerged: State courts will try a new rationale for extending personal jurisdiction; the Supreme Court will reject it; the States will try yet another variation; and the Supreme Court will reject it as well. That pattern continued in Bristol-Myers Squibb Co. v. Superior Court, 137 S. Ct. 1773 (2017), which the Supreme Court decided the last week of its recently finished term.
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