Brief Fact Summary.
Argentinian plaintiffs bring suit in a California court against a German company, based on the premise that the German company is subject to general jurisdiction in California because that’s where one of its subsidiaries is headquartered.
Synopsis of Rule of Law.
A court can exercise general jurisdiction over a corporation if the corporation’s connections to the forum state are so continuous and systematic as to render the corporation “at home” in the forum state.
As such, a corporation can purposefully avail itself of a forum by directing its agents or distributors to take action there.View Full Point of Law
Plaintiff alleges that Defendant Daimler AG’s subsidiary, Mercedes-Benz Argentina, colluded with security forces during the Argentinian civil war to kidnap, torture, and kill Mercedes-Benz Argentina personnel. MBUSA, also a Daimler AG subsidiary, was incorporated in New Jersey, imported cars from Germany, and sold them nationwide, including California. MBUSA also had a headquarters in California. Plaintiffs only sued Defendant Daimler AG but claimed that MBUSA acted as Daimler AG’s agent. Plaintiffs also argued that MBUSA was subject to general jurisdiction in California since it was headquartered there and therefore California could exercise jurisdiction over Daimler for the events that occurred during the war in Argentina.
Does due process allow an American court to exercise general jurisdiction over a foreign defendant in the absence of any American connection to the defendant, plaintiffs, or events in question?
No, an American court cannot exercise general jurisdiction over a foreign defendant unless that defendant has such continuous and systematic contacts with the forum state that the defendant can be considered “at home” in that forum state. Judgement of the Court of Appeals reversed.
Justice Justice Sotomayor
Agreed with the outcome but did not like the majority’s analysis. Believes the “at home” rule is too restrictive. She would have held California’s exercise of general jurisdiction unreasonable because the Plaintiffs could have sued Daimler in Germany.