Product Liability Lawsuit Against a Manufacturer In Another Jurisdiction
In Gray v. American Radiator & Standard Sanitary Corp., 22 Ill. 2d 432, 176 N.E.2d 761 (1961), the plaintiff was injured when a water heater exploded, as a result of an allegedly defective valve produced by the nonresident manufacturer defendant.
The Gray court concluded that jurisdiction was proper over the defendant because the "last event" was the exploding of the water heater, without which there would have been no injury to plaintiff and no tortious event.
Thus, although the defendant was never present in Illinois, the Gray court held that the tortious act occurred in Illinois because the place of a wrong was where the "last event" took place that was necessary to make the defendant liable. Gray, 22 Ill. 2d 432, 435, 176 N.E.2d 761.