There are many consequences to a Supreme Court decision besides its immediate holding. The recent opinion in Bristol Myers Squibb v. Superior Court (BMS), 137 S. Ct. 1773 (2017), is a perfect example. In BMS, the Court directly addressed litigation tourism and reiterated standards for establishing specific jurisdiction. But a closer read reveals that it also sounded the death knell of stream-of-commerce personal jurisdiction—a theory that the Supreme Court itself generated long ago and has been wrestling with for years. In essence, BMS cast aside the notion that globalization could justify 50-state forum shopping.

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