Gray v. American Radiator & Standard Sanitary Corp.
176 N.E.2d 761 (Ill. 1961)

  • A valve made by Titan (an Ohio company) was put into an American Radiator Brand Radiator in Pennsylvania. The radiator exploded and injured a guy named Gray in Illinois.
  • Gray sued American Radiator in Illinois. American Radiator argued that they could not be sued in Illinois because they didn’t sell radiators in Illinois and so had no continuing contacts with Illinois, and so the Illinois Court did not have jurisdiction.
    • See International Shoe v. Washington (326 U.S. 310 (1945)).
  • The Illinois Supreme Court found that Illinois had jurisdiction to hear the case.
    • The Illinois Supreme Court found that that once an item has been put into the stream of commerce, then that item becomes your agent for service of process.
  • This case was one of the first cases decided after Illinois passed their long-arm Statute. Illinois was the first state to pass such a statute.
  • This case was the basis in the Illinois Rule, which says that a tort resulting in damage inside the State is deemed to have occurred in the State regardless of where the tortious act took place.
    • Conversely, New York Rule (established in another case) says that a tort is only deemed to have been committed in a State if the tortious act is deemed to have been committed there, and not merely the injury resulting therefrom occurred therein.