In Montana, an accident involving a separated tire tread on a Ford Explorer caused the death of the driver, Markkaya Gullett.

In Minnesota, Adam Bandemer rear-ended a snow plow in a Ford Crown Victoria, causing him to end up in a ditch, but the car's air bags failed to deploy and he suffered a brain injury.

[1] In both cases, the parties (Gullett's estate and Bandemer) filed suit against Ford over defects in their products in their respect state courts.

"[1] Thus, the states had ample reason to find that the claim made "arise out of or relate to" Ford's activities, as established by the Due Process Clause.

Gorsuch favored a simpler "But-for" causation test instead, noting that the majority's decision might have a disparate impact on small businesses.