Appellate Court Finds Minnesota Courts Have Personal Jurisdiction Over Samsung in Lawsuit Faulting ‘Exploding’ E-Cig Battery
Envision a routine morning commute shattered by flames erupting from your pocket—second- and third-degree burns searing sensitive skin, all because a lithium-ion battery in your e-cigarette decided to detonate without warning. That’s the nightmare Shawn Peters endured in 2020, and now, a pivotal Minnesota appeals court ruling greenlights his quest for justice against tech giant Samsung, potentially unlocking a floodgate for similar claims nationwide.
On October 13, 2025, the Minnesota Court of Appeals delivered a resounding win for Peters, affirming that state courts can haul South Korean battery maker Samsung SDI Co., Ltd. (SDI) into Minnesota jurisdiction for the fiery fiasco. In a 21-page opinion, the panel reversed a lower court’s initial dismissal bid, ruling that SDI’s massive shipments of the explosive 18650 lithium-ion cells into the state—coupled with its foreknowledge of their resale for e-cigs—satisfy due process requirements for specific personal jurisdiction. The decision sends the case barreling toward trial, where Peters’ strict and negligent products-liability claims will finally face the merits.
The Blast That Sparked a Battle
The ordeal unfolded on January 7, 2020, when Peters, a Minnesota resident, arrived at work in the Twin Cities. The Samsung 18650 battery—tucked in his left front pocket to power his e-cigarette—suddenly ignited, spewing chemicals, smoke, and flames that inflicted horrific second- and third-degree burns to his genitalia, groin, thigh, and hand. Paramedics rushed him to a Minneapolis hospital, where he endured excruciating treatment for injuries that upended his life. Peters had bought the battery just months earlier, in late 2019, from local vape shops Infinite Vapors and Uptown Vapors—both Minnesota outfits stocking the cells for consumer use in vaping devices.
Peters fired off his lawsuit in March 2023 in Hennepin County District Court, targeting SDI alongside the retailers, Samsung SDI America, and unnamed defendants. He alleged the battery’s design and manufacturing flaws turned it into a ticking time bomb, breaching safety standards and failing to warn users of risks like thermal runaway. The case ping-ponged: Removed to federal court, then remanded to state level in July 2023, where an amended complaint fleshed out SDI’s deep Minnesota ties.
Jurisdiction Tug-of-War: Stream of Commerce Seals the Deal
SDI fought tooth and nail to dodge the suit, arguing Minnesota lacked personal jurisdiction over the foreign entity—it never directly sold standalone batteries to consumers or authorized e-cig use. In August 2023, the company moved to dismiss, backed by affidavits claiming its Minnesota dealings were limited to bulk shipments in sealed packs to industrial manufacturers. The district court initially sided with SDI in part but denied full dismissal after jurisdictional discovery unearthed damning evidence: Between 2017 and 2022, SDI funneled nearly 3 million 18650 cells to three Minnesota manufacturers under long-term supplier contracts, complete with Minnesota choice-of-law and forum-selection clauses.
On appeal, the Court of Appeals—reviewing de novo—applied Minnesota’s long-arm statute (Minn. Stat. § 543.19), which stretches as far as the U.S. Constitution permits. Zeroing in on due process, the judges invoked the five-factor test from Rilley v. MoneyMutual (2016): quantity and nature/quality of contacts, connection to the claim, state’s interest, and parties’ convenience. Four factors slammed in favor of jurisdiction; convenience stayed neutral.
Crucially, the court embraced the “stream of commerce plus” doctrine, citing U.S. Supreme Court precedents like World-Wide Volkswagen (1980) and Ford Motor Co. v. Montana (2021). SDI conceded purposeful availment via its Minnesota shipments but whiffed on minimum contacts, the panel ruled. “A manufacturer who places its product in the stream of commerce… is subject to suit in that jurisdiction,” the opinion quoted, noting SDI’s 2016 awareness that its cells were resold for e-cigs at U.S. vape shops. One supplier contract even flagged potential “resale… for personal, family, or household use,” torpedoing SDI’s “industrial-only” defense.
The connection factor was airtight: Peters’ injuries stemmed directly from an 18650 cell mirroring those millions shipped to Minnesota post-2016. Minnesota’s stake? Providing redress for a local resident scorched on home soil. As the court put it: “Minnesota has an interest in the litigation if the case involves a resident who was severely injured and the accident took place in Minnesota.” Fair play? Check—SDI’s global ops make travel a wash, and it could’ve foreseen suits in resale hotspots.
Cheers from the Bar, Silence from Seoul
Plaintiff’s counsel at Bentley & More LLP hailed the ruling as a “landmark victory,” crediting partners Greg Bentley and Matt Clark for unearthing the shipment data during discovery. This isn’t their first rodeo: The firm pioneered the nation’s inaugural e-cig injury jury verdict in 2015 and has battled Samsung and LG Chem in hundreds of cases, pushing for beefier regs and warnings. “Samsung can’t hide behind borders when its batteries torch Americans,” Bentley told reporters, vowing to press for accountability on liability and damages.
Legal eagles see broader ripples. “This aligns with federal circuits like the Sixth and Fifth, rejecting ‘different market’ dodges,” noted products liability prof Elena Satterfield of O’Melveny & Myers, who tracks battery suits. Echoing Sullivan v. LG Chem (6th Cir. 2023) and Ethridge v. Samsung (5th Cir. 2025), it bolsters plaintiffs in red states hungry for local forums. SDI, mum so far, may petition the Minnesota Supreme Court, but odds favor remand to district court for trial.
Stakes High for Vapers, Makers, and the Heartland
For everyday U.S. readers, this hits the vape pen where it hurts—literally. With e-cigs booming among 2.5 million youth and 28 million adults, lithium-ion blasts have scorched hundreds, per CPSC data, often in pockets for gruesome genital and thigh injuries. Economically, it spotlights supply chain perils: Samsung’s batteries power everything from EVs to gadgets, but unchecked resale risks jack up liability costs—think the $10.8 million Georgia verdict against SDI in June 2025 for a similar vape inferno.
Lifestyle fallout? Burn survivors grapple with chronic pain, scarring, and intimacy woes, amplifying mental health strains in a post-pandemic world. Politically, it amps calls for FDA crackdowns on unregulated vape mods; technologically, it nudges battery innovators toward safer chemistries amid Biden-era green pushes clashing with Trump’s fossil tilt. For Midwest families like Peters’, it’s validation: Your home court can summon global giants when they fuel local fires.
Barring higher appeals, Peters’ trial looms, probing SDI’s design sins and payout for his “grievous injuries.” As the court wrapped: Exercising jurisdiction “comports with notions of fair play and substantial justice.” In an era of borderless commerce, this ruling reminds multinationals: Ship here, answer here—especially when the cargo combusts.
By Sam Michael
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