Battery Jurisdiction Case Reverses Polarity

Inspired by a recent Seventh Circuit case involving similar facts (and the benefit of jurisdictional discovery), the Fifth Circuit reheard Ethridge v. Samsung and concluded that there was not personal jurisdiction in Texas over the plaintiff’s claim to have been injured by a flammable battery made by Samsung.

The new opinion summarizes: “Nothing in this opinion should be construed as answering whether the precise measures Samsung took to sell its products only to the industrial market create a necessary baseline for specific personal jurisdiction cases like this one. It is enough to say that Samsung affirmatively limited its contacts to approved manufacturers in Texas, and Ethridge has not shown that his injuries are related to those contacts.” No. 23-40094 (Dec. 15, 2025, on rehearing).