Daimler AG v. Bauman

187 L. Ed. 2d 624 · Supreme Court of the United States · 2014

Facts

Twenty-two Argentinian residents sued German company Daimler in California federal court, alleging its Argentinian subsidiary collaborated in human rights abuses during Argentina's "Dirty War." Jurisdiction over Daimler was based on the California contacts of its U.S. subsidiary, MBUSA, which distributes vehicles in the state.

Issue

Does the Due Process Clause permit a U.S. court to exercise general personal jurisdiction over a foreign corporation based on its U.S. subsidiary's in-state contacts, when the claims arise entirely from conduct outside the U.S. and are unrelated to the subsidiary's activities?

Holding

No, the Supreme Court reversed, finding that Daimler's affiliations with California, even when attributing MBUSA's contacts, were insufficient to render it "at home" in the state, thus precluding general personal jurisdiction for claims unrelated to California.

Rule

General personal jurisdiction over a corporation is proper only when its affiliations with the forum state are so "continuous and systematic" as to render it "essentially at home" there, typically its place of incorporation or principal place of business. An agency theory based on the "importance" of a subsidiary's services is insufficient to establish general jurisdiction.

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