Washington Legal Foundation's Legal Backgrounder

Authors: James M. Beck Michelle L. Cheng

The U.S. Supreme Court’s rulings in Goodyear Dunlop Tires Operations, S.A. v. Brown (2011) and Daimler AG v. Bauman (2014) have resulted in the limitation of “general” personal jurisdiction that previously existed under the International Shoe v. Washington (1945) decision. A non-resident corporation doing significant business in a particular state does not necessarily qualify as the subject of potential lawsuits in the jurisdiction of that state. In fact, the Goodyear and Bauman decisions have established that general jurisdiction can only be asserted against corporate defendants in three areas:

  • The corporation’s state of incorporation
  • The corporation’s principal place of business
  • “In an exceptional case,” a state in which the corporation’s activities are “so substantial and of such a nature as to render the corporation at home in that State”

As a result of these rulings, corporate defendants operating in multiple states should examine a lawsuit’s jurisdiction according to the criteria above to determine whether such a lawsuit is valid within that jurisdiction.

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