Daimler AG v. Bauman

571 U.S. 117, 134 S. Ct. 746 (2014)

 

RULE:

All-purpose jurisdiction speaks of instances in which the continuous corporate operations within a state are so substantial and of such a nature as to justify suit on causes of action arising from dealings entirely distinct from those activities. Accordingly, the inquiry is whether that corporation’s affiliations with the State are so continuous and systematic as to render it essentially at home in the forum State.

FACTS:

A class action suit was filed by Argentinian residents in California against against DaimlerChrysler Aktiengesellschaft , a German public stock company, headquartered in Stuttgart, Germany. The complaint alleged that Daimler’s Argentinian subsidiary, Mercedes-Benz Argentina, committed several human rights violations. Jurisdiction over the lawsuit was predicated on the California contacts of Mercedes-Benz USA, LLC (MBUSA), a subsidiary of Daimler incorporated in Delaware with its principal place of business in New Jersey.

ISSUE:

Does a state court have jurisdiction over a claim against a foreign corporation that does not conduct any form of business within the state?

ANSWER:

No.

CONCLUSION:

The corporation's slim contacts with the state were not so continuous and systematic as to render the corporation essentially at home in the state and subject to suit in the state for claims of the foreign residents for conduct which did not occur in or impact the state. Further, neither the corporation nor the U.S. subsidiary were incorporated or had a principal place of business in the state, which were paradigm bases for general jurisdiction, and the transnational context of the dispute implicated risks to international comity from the broad assertion of general jurisdiction.

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