Key points
- A Samsung 18650 battery exploded causing burns to a user in Minnesota, USA, leading to a product liability lawsuit.
- Samsung claimed that they did not directly sell the battery nor target consumers.
- An investigation revealed that Samsung SDI sold approximately 2.9 million 18650 batteries to three manufacturers in Minnesota for industrial equipment and consumer products.
- The contracts included Minnesota law and judicial selection clauses, indicating "active market engagement."
- The court found minimal contacts and upheld the original decision, moving the e-cigarette explosion case into the substantive trial phase.
2Firsts, October 17, 2025 — Judge Bratvold of the Minnesota Court of Appeals concluded that Samsung SDI “deliberately engaged in and benefited from business activities in Minnesota” and therefore must face litigation in the state.
Court documents revealed that between 2017 and 2022, Samsung SDI sold approximately 2.9 million 18650 lithium-ion cells to three Minnesota-based manufacturers. These contracts incorporated Minnesota law and venue provisions. Although Samsung SDI argued that it only sold “sealed battery packs” not accessible to consumers, the court determined that the company was aware its products were being resold and used in e-cigarette devices.
The opinion noted that internal investigations as early as 2016 confirmed that 18650 batteries were available for retail purchase in U.S. vape stores. The court held this constituted foreseeability — meaning Samsung SDI should have anticipated being sued in Minnesota over consumer injuries.
Citing the U.S. Supreme Court’s decision in Ford Motor Co. v. Montana Eighth Judicial District Court (2021), the panel reasoned that a manufacturer’s substantial commercial activity in a state, even if indirect, is sufficient to establish jurisdiction when injuries relate to those activities.
The court further emphasized that the plaintiff purchased the product, suffered injury, and received medical treatment in Minnesota — giving the state a strong interest in providing a forum for relief. While the defendant’s witnesses would need to travel internationally, the convenience factor was deemed neutral.
The appellate court affirmed the lower court’s ruling, allowing the lawsuit to proceed to trial on the merits of the product-liability claims. The decision aligns with rulings from the Fifth and Sixth Circuits rejecting the “different market” defense raised by 18650 battery manufacturers. Legal experts suggest the case may signal growing exposure for global battery and vaping product makers under U.S. state-level jurisdiction.
Image source: law.justia
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