LAW 521-002 – Civil Procedure I

McIntyre Rule


In J. McIntyre, Ltd. v. Nicastro, the Supreme Court had a 4/2/3 split on stream of commerce.

The plurality view was that stream of commerce alone is not enough to constitute purposeful availment.

Differs from the Asahi Rule, but since McIntyre had no majority, Asahi was not overruled.