Tennessee v. NV Sumatra Tobacco Trading Co.

The State of Tennessee sought to recoup money owed to it under legislation related to the 1998 Master Settlement Agreement (MSA) for cigarettes sold in the state.  Under the MSA and Tennessee law, tobacco manufacturers who did not agree to settle were required to establish escrow accounts in states where they continued to sell cigarettes.  In this case, an Indonesian tobacco manufacturer sold cigarettes through a series of intermediaries that eventually were sold to consumers in Tennessee.  Neither the distributor in the U.S. nor the manufacturer paid any money into the escrow accounts as required by the MSA.  The manufacturer challenged the case by claiming that Tennessee courts did not have personal jurisdiction over the company under the due process clause of the 14th amendment.  After conflicting conclusions in the lower courts, the Tennessee Supreme Court found the company did not have the necessary minimum contacts necessary to establish personal jurisdiction.  The court said the company did not purposely avail itself of the state's laws and the contacts with the state were attributable to uncontrolled third parties.  The court upheld the trial court's ruling and dismissed the case.

State of Tennessee v. NV Sumatra Tobacco Trading Co., No. M2010-01955-SC-R11-CV (Tenn. 2013)

  • United States
  • Mar 28, 2013
  • Supreme Court of Tennessee
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Parties

Plaintiff State of Tennessee

Defendant NV Sumatra Tobacco Trading Company

Legislation Cited

Master Settlement Agreement

U.S. Constitution, 14th Amendment

Related Documents

Type of Litigation

Tobacco Control Topics

Substantive Issues

Type of Tobacco Product

None

"This record reveals that NV Sumatra had no meaningful contacts with Tennessee. Beyond the act of placing its United brand cigarettes in the international stream of commerce, NV Sumatra's targeted behavior was minimal at most. It had no specific interest in Tennessee. The company's awareness - largely after the fact - that its cigarettes were being sold in Tennessee fails to evidence purposeful availment of the Tennessee market. Based on the attenuated nature and quality of the sales of NV Sumatra's cigarettes in Tennessee, we do not find that these sales amounted to minimum contacts sufficient for NV Sumatra to reasonably expect being hauled into Court in Tennessee. The International Shoe does not fit; NV Sumatra cannot wear it."