Law School Case Brief
Goodyear Dunlop Tires Operations, S.A. v. Brown - 564 U.S. 915, 131 S. Ct. 2846 (2011)
Opinions in the wake of the pathmarking International Shoe decision have differentiated between general or all-purpose jurisdiction, and specific or case-linked jurisdiction. A court may assert general jurisdiction over foreign (sister-state or foreign-country) corporations to hear any and all claims against them when their affiliations with the State are so "continuous and systematic" as to render them essentially at home in the forum State. Specific jurisdiction, on the other hand, depends on an affiliation between the forum and the underlying controversy, principally, activity or an occurrence that takes place in the forum State and is therefore subject to the State's regulation. In contrast to general, all-purpose jurisdiction, specific jurisdiction is confined to adjudication of issues deriving from, or connected with, the very controversy that establishes jurisdiction.
Two boys from North Carolina died in a bus accident that occurred in France. Attributing the accident to a tire that failed, their parents alleged negligence in the design, construction, testing, and inspection of the tire, which was manufactured in Turkey. The three subsidiaries were incorporated in Turkey, Luxembourg, and France and manufactured tires primarily for sale in European and Asian markets. A small percentage of their tires were distributed within North Carolina by other affiliates. A case was filed in North Carolina. The trial court denied the subsidiaries’ motion to dismiss the claims against them for want of personal jurisdiction. The North Carolina Court of Appeals affirmed, concluding that the North Carolina courts had general jurisdiction over petitioners, whose tires had reached the State through “the stream of commerce.” The case was elevated on writ of certiorari to the Supreme Court of the United States.
Could North Carolina exercise jurisdiction over the case?
The Supreme Court determined that the subsidiaries were not amenable to general jurisdiction in North Carolina courts because their attenuated connections to the State fell far short of the continuous and systematic general business contacts necessary to empower North Carolina to entertain suit against them on claims unrelated to anything that connected them to the State. The sporadic sales of the subsidiaries' tires in North Carolina through intermediaries were insufficient to warrant the assertion of general jurisdiction.
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Endeavoring to give specific content to the "fair play and substantial justice" concept, the Supreme Court has classified cases involving out-of-state corporate defendants. First, jurisdiction unquestionably could be asserted where the corporation's in-state activity is "continuous and systematic" and that activity gave rise to the episode-in-suit. Further, the commission of certain "single or occasional acts" in a State may be sufficient to render a corporation answerable in that State with respect to those acts, though not with respect to matters unrelated to the forum connections. The heading courts today use to encompass these two International Shoe categories is "specific jurisdiction." Adjudicatory authority is "specific" when the suit arises out of or relates to the defendant's contacts with the forum.