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Goodyear Dunlop Tires Operations v. Brown

Supreme Court of the United States · 2011 · Civil Procedure

Civil Procedurepersonal jurisdictiongeneral jurisdictionessentially at homeforeign corporationspersonal jurisdictiongeneral jurisdictionspecific jurisdiction

Facts

The suit arose from a bus accident outside Paris, France, allegedly caused by a defective tire manufactured in Turkey by a foreign subsidiary of Goodyear USA. The foreign subsidiaries were incorporated and operated in Turkey, France, and Luxembourg, and they were not registered to do business in North Carolina, had no place of business, employees, or bank accounts there, and did not design, manufacture, advertise, sell, or ship tires there themselves. A small percentage of their tires reached North Carolina through other Goodyear affiliates, but the type of tire involved in the accident was never distributed in North Carolina. The accident occurred abroad, and the allegedly defective tire was manufactured and sold abroad.

Issue

May North Carolina courts exercise general personal jurisdiction over foreign subsidiaries of a United States parent corporation when the claims do not arise from the subsidiaries' activities in North Carolina and only a small percentage of their products reached the State through the stream of commerce?

Rule

A state court may assert general jurisdiction over a foreign corporation only when the corporation's affiliations with the forum are so continuous and systematic as to render it essentially at home in the forum State. The flow of a manufacturer's products into the forum may support specific jurisdiction when the suit arises from those forum-connected activities, but that kind of connection does not by itself support general jurisdiction over claims unrelated to the forum contacts. Continuous activity of some sort within a state is not enough to make a corporation amenable to suits unrelated to that activity.

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

Sora Mobility GmbH, a German scooter manufacturer, has no offices, employees, bank accounts, or registration in Oregon. A small number of its scooters reach Portland each year through an affiliated distributor, but the lawsuit concerns a crash in Chile involving a scooter Sora made and sold in South America.

If the injured rider sues Sora in Oregon state court, what is the strongest argument against Oregon's exercise of general personal jurisdiction?

Explanation. General jurisdiction over a corporation exists only when its affiliations with the forum are so continuous and systematic as to render it essentially at home there. Product flow into the forum may support specific jurisdiction when the suit arises from those forum-connected events, but it does not by itself create all-purpose jurisdiction for an unrelated foreign accident. (Derived from Goodyear Dunlop Tires Operations v. Brown (2011).)