Fanuc: California Jurisdiction Over a Foreign Robot Manufacturer After an Industrial Injury

In Fanuc Corp. v. Superior Court, No. E086688 (Cal. Ct. App. Oct. 9, 2026), the California Court of Appeal, Fourth District, Division Two, held that a Japanese robotics manufacturer was not subject to personal jurisdiction in California state court for a third-party workplace injury lawsuit where the record contained no evidence that the foreign parent or its domestic subsidiary marketed, sold, or installed the specific robot model in California.

Facts Chronology and Procedural Posture

In June 2020, Abraham Bernal worked as a maintenance technician at a Niagara Bottling LLC facility in California. During his shift, an industrial depalletizer machine and an articulated robot malfunctioned. Bernal was tasked with troubleshooting the equipment. As he was securing a ladder below the depalletizer's gripper head—which was positioned 15 to 20 feet above the floor—the depalletizer released the gripper head, causing severe physical injuries.

The depalletizer was manufactured by Krones, Inc. (Krones). The robot was manufactured by Fanuc Corporation (Fanuc Japan), a Japanese corporation with its principal place of business in Japan. Bernal filed a civil tort complaint in the Superior Court of San Bernardino County against Krones, Fanuc Japan, and Fanuc America Corporation (Fanuc America), a wholly owned subsidiary of Fanuc Japan incorporated in Delaware with its principal place of business in Michigan.

Fanuc America did not contest personal jurisdiction. Fanuc Japan specially appeared and filed a motion to quash service of summons for lack of personal jurisdiction pursuant to California Code of Civil Procedure section 418.10, subdivision (a)(1). In support of the motion, a Fanuc Japan executive submitted a declaration stating that Fanuc Japan:

• Was organized under Japanese law with its principal place of business in Japan;
• Was not registered to do business in California, maintained no California offices, bank accounts, or property; and
• Manufactured the specific robot involved in the incident (model M-410iB/700) in Japan and distributed it to FANUC Europe Corporation or its European subsidiaries ; the declaration did not explain how the robot subsequently reached California. Fanuc, slip op. at 3, 17 n.5.

In opposition, Bernal argued that general jurisdiction existed because Fanuc America acted as Fanuc Japan's agent and alter ego in California. Bernal also asserted specific jurisdiction based on Fanuc Japan's global marketing, interlocking corporate boards, research collaborations with California universities, and Fanuc America's operation of three California service locations.

The San Bernardino Superior Court (Judge David E. Driscoll) denied Fanuc Japan's motion to quash, concluding that Fanuc Japan was subject to general jurisdiction under an agency theory and referring to a separate ruling that it described as showing evidence of a single enterprise. The appellate court did not treat that reference as a conclusive alter-ego finding. Fanuc, slip op. at 4, 12 n.3. Fanuc Japan petitioned the Court of Appeal for an extraordinary writ of mandate, and the appellate court issued an order to show cause.

Precise Legal Questions Presented

The Fourth District Court of Appeal addressed two primary constitutional questions:

• General Jurisdiction: Can general (all-purpose) personal jurisdiction be imputed to a foreign parent corporation based on the forum contacts of its domestic subsidiary under agency or alter ego theories, when neither the parent nor the subsidiary is incorporated or maintains its principal place of business in California?
• Specific Jurisdiction: Can specific (case-linked) personal jurisdiction be asserted over a foreign manufacturer of industrial equipment under Ford Motor Co. v. Montana Eighth Judicial District Court (2021) when the plaintiff fails to present evidence that the foreign manufacturer or its domestic agent marketed, sold, or installed the specific model of equipment in the forum state?

Step-by-Step Argument and Judicial Reasoning

Writing for a unanimous panel, Justice Raphael analyzed general and specific personal jurisdiction separately under federal Fourteenth Amendment due process principles. Because the jurisdictional evidence was not conflicting, the court reviewed the legal issue independently. Fanuc, slip op. at 4–6.

1. General Jurisdiction Analysis Under Daimler

The court reaffirmed that general jurisdiction permits a court to hear any and all claims against a foreign corporation only when its affiliations with the state are so continuous and systematic as to render it "essentially at home" in the forum state (citing Goodyear Dunlop Tires Operations, S.A. v. Brown (2011) and Daimler AG v. Bauman (2014)).

The paradigm forums where a corporation is at home are its place of incorporation and its principal place of business. Fanuc Japan is incorporated in Japan with its principal place of business in Japan. It has no offices, property, bank accounts, or corporate registration in California. Consequently, direct general jurisdiction was absent.

The court held that the trial court erred in imputing general jurisdiction to Fanuc Japan based on an agency theory. Under Daimler, the United States Supreme Court invalidated broad agency and "representative services" doctrines that previously allowed general jurisdiction whenever a domestic subsidiary performed services that the foreign parent would otherwise perform itself. Furthermore, even assuming an agency or alter ego relationship existed between Fanuc Japan and Fanuc America, Fanuc America is incorporated in Delaware and headquartered in Michigan. Because Fanuc America itself is not "essentially at home" in California, imputing its contacts did not make Fanuc Japan essentially at home in California on this record. Fanuc, slip op. at 10–12.

The same obstacle defeated the proposed alter-ego route even if that relationship were assumed. The court also noted that Bernal had not supplied the separate summary-judgment ruling as an exhibit; the described ruling appeared at most to identify evidence for a later factfinder, not conclusively establish alter ego. Fanuc, slip op. at 12 n.3.

2. Specific Jurisdiction Analysis Under Ford Motor Co.

Specific jurisdiction requires three elements: (1) purposeful availment by the defendant of the privilege of conducting activities in the forum; (2) claims that arise out of or relate to the defendant's contacts with the forum; and (3) reasonableness. The Court of Appeal assumed, but did not decide, that Fanuc America acted as an agent and that purposeful availment could be shown through its actions. It confined the analysis to relatedness and did not reach reasonableness. Fanuc, slip op. at 13–14.

Under Ford Motor Co. v. Montana Eighth Judicial District Court (2021) 592 U.S. 351, proof of strict causal connection is not always required, but the court examined whether the record showed a relevant relationship between the claim and the defendant’s forum activities. Systematic service of the market for the vehicle models involved mattered to the Ford comparison. Fanuc, slip op. at 14–17. In Ford, the manufacturer heavily advertised, sold, and serviced the exact vehicle models (Explorer and Crown Victoria) in the forum states for many years.

Applying Ford, the Court of Appeal found that Bernal failed to prove relatedness regarding the Fanuc robot model M-410iB/700:

• Bernal did not identify evidence of California marketing, sales, or installation of the model sufficient for the relatedness showing. Fanuc, slip op. at 16–17.
• The fact that Bernal's employer purchased other robot models from Fanuc America did not establish that the claims related to the specific model at issue. The cited testimony did not identify those other robots as the same model, and the court resolved the ambiguity against the party bearing the burden. Fanuc, slip op. at 17 n.6.
• Fanuc America's operation of three California service locations and a single post-incident repair of the subject robot did not satisfy the relatedness requirement, as there was no evidence that California service centers systematically serviced or exploited the California market for that specific model line on the record presented. Fanuc, slip op. at 17–18.

Because Bernal failed to meet his initial burden on relatedness, the court did not reach the third element of reasonableness.

Panel and Exact Disposition

Panel: Opinion by Justice Raphael, with Presiding Justice Ramirez and Justice Miller concurring.

Exact Disposition: Extraordinary writ of mandate GRANTED. The Court of Appeal reversed the trial court's order denying Fanuc Japan's motion to quash service of summons and remanded the matter to the San Bernardino County Superior Court with directions to enter a new order granting the motion to quash service as to Fanuc Japan only. Fanuc Japan was awarded its costs on the writ proceeding. (Fanuc Corp. v. Superior Court, printed opinion pp. 1–20).

Practical Significance, Limits, and Current Law

The decision in Fanuc Corp. v. Superior Court carries major practical implications for third-party workplace injury litigation in California involving foreign machinery manufacturers:

• No Effect on Statutory Workers' Compensation: The ruling addresses civil personal jurisdiction in state court under Code of Civil Procedure section 418.10. It did not adjudicate the injured worker’s eligibility for workers’ compensation benefits.
• Model-Specific Discovery Required: Plaintiffs bringing product liability claims against foreign equipment manufacturers cannot rely on generalized parent-subsidiary ties or generic corporate brand presence. Discovery must focus specifically on whether the foreign parent or its domestic distributor targeted California for the precise equipment model that caused the harm.
• First Sale Outside California Is Not a Categorical Bar: The court explicitly noted that an initial sale in Europe does not categorically preclude specific jurisdiction in California. If a plaintiff presents a record showing systematic regional marketing, sales, or installation of that specific equipment model in California, that evidence would require a claim-specific jurisdiction analysis; the court expressly left open a different record or claim. Fanuc, slip op. at 19.
• Distinction Between Equipment Entities: The order quashes service against Fanuc Japan only. It does not decide the merits, liability, or continued viability of claims against Krones or Fanuc America. Fanuc, slip op. at 2, 20.

Related Analysis

Primary source: Fanuc Corp. v. Superior Court, No. E086688 (Cal. Ct. App. Oct. 9, 2026), official opinion. For the practical investigation task, see our Industrial Machine Injury Evidence Guide and California Workers' Compensation Practice Area.