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Daimler AG v. Bauman

Supreme Court of the United States · 2014 · Civil Procedure

Civil Procedurepersonal jurisdictiongeneral jurisdictionessentially at homepersonal jurisdictiongeneral jurisdictionall-purpose jurisdictionspecific jurisdiction

Facts

Twenty-two Argentinian residents sued Daimler, a German corporation headquartered in Stuttgart, alleging that Daimler's Argentinian subsidiary collaborated with Argentinian state security forces during the Dirty War to kidnap, detain, torture, and kill workers in Argentina. No part of the alleged misconduct occurred in California or elsewhere in the United States, and plaintiffs sought to invoke only general jurisdiction. Plaintiffs relied on the California contacts of Mercedes-Benz USA, a Delaware LLC with its principal place of business in New Jersey that distributed Daimler vehicles nationwide and had California facilities and substantial California sales. Daimler's own California contacts were not argued to be sufficient by themselves, and plaintiffs did not claim MBUSA was Daimler's alter ego.

Issue

Whether the Due Process Clause permits California courts to exercise general personal jurisdiction over Daimler, a foreign corporation, for claims brought by foreign plaintiffs arising from conduct occurring entirely abroad, based on the California contacts of Daimler's in-state subsidiary distributor. More specifically, the question was whether those contacts rendered Daimler essentially at home in California.

Rule

A court may assert general jurisdiction over a corporation only when the corporation's affiliations with the forum state are so continuous and systematic as to render it essentially at home there. For a corporation, the paradigm forums are its place of incorporation and its principal place of business; a subsidiary's in-state contacts cannot be attributed under an expansive agency theory that would effectively make any substantial in-state affiliate enough to create all-purpose jurisdiction.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

North Harbor Robotics, Inc. is incorporated in Delaware and maintains its principal executive headquarters in Illinois. A resident of Peru sues the company in Illinois state court over an injury that occurred at the company's warehouse in Lima and has no connection to Illinois.

Assuming the plaintiff relies only on general personal jurisdiction, is Illinois a proper forum?

Explanation. General jurisdiction permits suit on any and all claims only where the corporation is essentially at home. The majority identified the paradigm forums for a corporation as its place of incorporation and principal place of business. Because Illinois is North Harbor Robotics's principal place of business, Illinois may exercise general jurisdiction even though the claim arose abroad and is unrelated to Illinois. (Derived from Daimler AG v. Bauman (2014).)