Daimler AG v. Bauman
January 14, 2014
Case #: 11-965
Ginsburg, J., delivered the opinion of the Court, in which Roberts, C. J., and Scalia, Kennedy, Thomas, Breyer, Alito, and Kagan, JJ., joined. Sotomayor, J., filed an opinion concurring in the judgment.
Full Text Opinion: http://www.supremecourt.gov/opinions/13pdf/11-965_1qm2.pdf
Civil Procedure: Petitioner is not answerable to a suit in California for injuries which occurred outside of the United States.
Respondent alleges that Petitioner worked with state forces to kidnap, detain, torture and murder Petitioner's employees in Argentina. Personal jurisdiction was based on contacts held by a subsidiary of Petitioner in California. The District Court granted Petitioner's motion to dismiss for lack of personal jurisdiction. On appeal, the Ninth Circuit reversed and held that the subsidiary was an agent for jurisdictional purposes which made Petitioner answerable to suit in California.
The Supreme Court reversed and held that Petitioner is not answerable to a suit in California for injuries which occurred outside of the United States. The Court reasoned that general jurisdiction exists when operations are continuous, substantial and of such a nature to justify a suit based on a cause of action arising from dealings distinct from those operations. Petitioner is not incorporated nor is Petitioner's principal place of business in California and thus no general jurisdiction exists in California. Additionally, extending jurisdiction due to a subsidiary's services that are "important" to a corporation would make general jurisdiction overbroad.