Morris v. Halsey Enterprises Co

In Morris v. Halsey Enterprises Co., 379 Ill. App. 3d 574, 581-82, 882 N.E.2d 1079, 317 Ill. Dec. 923 (2008), the plaintiff was injured by a fan which fell from a ceiling. The manufacturer of the fan, Halsey Enterprises Company (Halsey), was located in Taiwan and constructed ceiling fans for Casablanca Fan Company (Casablanca), which was incorporated in Illinois. Halsey was aware that hundreds of thousands of its product were distributed and marketed nationally through a network of lighting stores and national retail chains, including Home Depot and Lowe's. Halsey would also ship fans directly to Casablanca's distributors, but did not have any knowledge that any of Casablana's distributors were actually located in Illinois. Furthermore, Halsey had no control over the actual distribution of its fans within this country, was not aware of which states its products were ultimately marketed or sold in, and was never informed that its products were being distributed or sold in Illinois. The Court found that sufficient minimum contacts did not exist to justify the exercise of personal jurisdiction over Halsey. Morris, 379 Ill. App. 3d at 583.