Goodyear Dunlop Tires Operations, S.A. v. Brown

Brief Fact Summary.

Plaintiffs sued Defendants in North Carolina for negligently making the tire that caused the bus accident in France. Defendants moved to dismiss the case for lack of personal jurisdiction.

Synopsis of Rule of Law.

Consistent with the Due Process Clause, a court may assert general jurisdiction over foreign corporations when the corporation’s affiliations with the state are so “continuous and systematic” as to render them essentially at home in the forum state.

Facts.

After two young boys from North Carolina were killed in a bus accident in Paris, France, the boys’ parents (Plaintiffs) brought suit in North Carolina against Goodyear Tire and Rubber Company, an Ohio company, and three of is subsidiaries operating in Turkey, France, and Luxembourg (Defendants). The Defendants had no place of business, employees, or bank accounts in North Carolina, nor did they design, manufacture, advertise, sell, or ship products to the state. On these facts, the Defendants moved to dismiss the case for lack of personal jurisdiction.

Issue.

Does a state court have personal jurisdiction over foreign corporations when the underlying controversy is not connected to the forum state and the corporations have no continuous and systematic affiliation to the forum state?

Held.

No, the forum state does not have general jurisdiction or specific jurisdiction over foreign subsidiaries. The lower court’s decision is reversed.

Discussion.

The Court agreed with the lower courts that North Carolina lacked specific jurisdiction over the Defendants because there was no connection between the underlying controversy which occurred abroad and the forum state. However, the Court determined that North Carolina also lacked general jurisdiction over the Defendants because the Defendants did not have sufficient connections to North Carolina to render it essentially at home in the state.