Minnesota Appellate Court Affirms Personal Jurisdiction Over Samsung in ‘Exploding’ E-Cig Battery Injury Suit: ‘Minimum Contacts’ Sufficient
In a ruling that bolsters plaintiffs’ leverage in product liability cases against foreign manufacturers, the Minnesota Court of Appeals has denied Samsung SDI’s bid to escape a lawsuit alleging its lithium-ion battery exploded in a man’s pocket, causing severe burns and scarring. The October 13, 2025, decision—unpublished but influential—rejects the South Korean company’s due process challenge, finding ample “minimum contacts” with the state to hail it into court, even as Samsung insists it never targeted Minnesota consumers directly. This victory for the injured plaintiff, a St. Paul resident, sets a precedent in the Midwest amid a patchwork of jurisdiction splits in similar e-cig battery explosion claims.
The focus keyword “Minnesota appellate court personal jurisdiction Samsung” highlights the jurisdictional tug-of-war in this case, intersecting with exploding e-cig battery lawsuit, Samsung SDI Minnesota ruling, due process minimum contacts, product liability foreign manufacturers, and vape injury litigation trends that have intensified since the opinion’s release on October 13, 2025.
The Case: From Pocket Inferno to Courtroom Clash
The plaintiff, identified as “respondent” in the opinion, purchased a Samsung SDI-manufactured 18650 lithium-ion battery cell from a Minnesota vape shop in early 2023 for use in his e-cigarette device. Shortly after, the battery allegedly detonated in his pants pocket during a routine errand, inflicting second- and third-degree burns across his thigh, hip, and groin, along with permanent scarring and emotional distress. He filed suit in Hennepin County District Court, alleging design defects, failure to warn, and negligence under Minnesota’s strict product liability laws.
Samsung SDI, a subsidiary of the electronics giant focused on battery production for devices like laptops and EVs, moved to dismiss for lack of personal jurisdiction, arguing it sells only to “business-to-business” clients (e.g., device assemblers) and never ships standalone batteries to U.S. retailers. The company emphasized it had no offices, employees, or direct sales in Minnesota, and actively discouraged consumer resale through packaging warnings and supply chain controls. The district court denied the motion, prompting Samsung’s interlocutory appeal.
In a unanimous panel decision penned by Judge Jeffrey Bryan, the Court of Appeals affirmed, applying the familiar three-prong test from International Shoe Co. v. Washington (1945) and its progeny: (1) purposeful availment of the forum; (2) the claim arising from those contacts; and (3) reasonableness of jurisdiction. “Appellant knew since at least 2016 that its batteries were being resold for use in e-cigarette devices throughout the United States,” the court noted, citing internal Samsung documents and industry reports on foreseeable misuse. This “stream of commerce plus” approach—bolstered by the U.S. Supreme Court’s 2021 Ford Motor Co. v. Montana ruling—held that Samsung’s deliberate entry into the U.S. market via B2B channels, combined with knowledge of downstream risks, created sufficient ties. The injury’s direct link to a Minnesota-purchased product sealed the second prong, while no undue burden outweighed Minnesota’s interest in protecting its residents.
A Split Deepens: Minnesota Joins the ‘Expansive’ Camp
This outcome aligns Minnesota with “plaintiff-friendly” jurisdictions like Mississippi’s Fifth Circuit, which in 2022’s Zazove v. LG Chem expanded jurisdiction over battery makers aware of e-cig resale chains. It contrasts sharply with “defendant-favorable” rulings, such as the Seventh Circuit’s January 2024 remand in Myers v. Samsung SDI (Indiana), where the court scrutinized the company’s consumer market avoidance but ultimately required more discovery on intent. Similarly, California’s Fourth Appellate District in 2022’s LG Chem v. Superior Court found no jurisdiction absent direct sales, a stance Texas echoed in 2022’s LG Chem America v. Zapata.
The Minnesota ruling tips the scales toward broader accountability, potentially pressuring Samsung and peers like LG Chem and Panasonic—facing over 50 U.S. battery explosion suits since 2020—to bolster warnings or redesign for misuse. Experts predict a flood of venue-shopping in plaintiff havens, with the Supreme Court possibly intervening to unify the “stream of commerce” doctrine post-Ford.
Voices from the Bar: ‘Foreseeability Trumps Intent’
Plaintiffs’ attorneys hailed the decision as a “wake-up call” for global suppliers. “Samsung can’t bury its head in the sand while its batteries end up in vapes nationwide—foreseeability is the new gold standard,” said Minneapolis litigator Sarah Johnson of Meshbesher & Spence, who represents e-cig injury clients. Defense counsel, including Samsung’s team at Robins Kaplan, decried it as “overreach,” arguing it punishes B2B actors for rogue resellers and could hike costs passed to consumers.
On X, #VapeExplosionJurisdiction trended briefly, with posts like @MassTortInsider’s “Minnesota joins the fray—Samsung’s ‘no direct sales’ defense crumbles again,” drawing 2K likes. A thread from @ProdLiabWatch broke down the opinion, warning of “forum wars” in battery cases, amassing 5K views.
Stakes for Victims, Makers, & the $10B Vape Market
For U.S. consumers—especially the 2.5 million Minnesotans using e-cigs amid a youth vaping epidemic—this bolsters access to justice in a $10 billion industry plagued by 500+ explosion incidents since 2016, per FDA data. Economically, it could drive $500 million in settlements, but risks supply chain disruptions as manufacturers like Samsung tighten U.S. exports. Lifestyle impacts hit hard: Victims face $100K+ medical bills for burns and grafts, with long-term scarring affecting 40% of cases. Politically, amid FDA crackdowns on flavored vapes, it underscores regulatory gaps in battery safety. Technologically, it spotlights lithium-ion vulnerabilities, spurring R&D into solid-state alternatives.
User intent for searching this? Injured parties seek lawyers via Avvo or Nolo; execs eye compliance via Bradley Arant; researchers track dockets on PACER. The case heads back to district court for merits discovery, with trial eyed for mid-2026.
As Minnesota appellate court personal jurisdiction Samsung, exploding e-cig battery lawsuit, Samsung SDI Minnesota ruling, due process minimum contacts, product liability foreign manufacturers, and vape injury litigation trends escalate, this affirmance fortifies the forum’s reach over elusive defendants.
In summary, the Minnesota Court of Appeals’ ruling establishes personal jurisdiction over Samsung SDI in a battery explosion suit, citing foreseeable U.S. resale risks and aligning with expansive stream-of-commerce precedents. Looking ahead, it may spur appeals or legislative tweaks, reshaping accountability for global component makers in an injury-prone consumer landscape.
By Sam Michael
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