Daimler AG v. Bauman: The Supreme Court Clarifies General (or “All-Purpose”) Personal Jurisdiction Over Corporations, Both Foreign and Domestic

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On January 14, 2014, the United States Supreme Court decided Daimler AG v. Bauman, which considered whether a corporation domiciled abroad can be subject to general personal jurisdiction in a U.S. court based on the activities of the foreign corporation’s U.S. subsidiary. A defendant over which a court has general jurisdiction can be subject to suit in that court on any claim, even those claims that are unrelated to the defendant’s activities in the forum state.

The Supreme Court, in a unanimous decision by Justice Ruth Bader Ginsburg (with Justice Sonia Sotomayor concurring in the judgment), held that it violates due process for a court to exercise general personal jurisdiction over a corporation that is not “at home” in the forum state. A corporation, the Court explained, is not “at home” all over the country or the world. It is “at home”—and therefore subject to general jurisdiction—where it is incorporated, where it has its principal place of business, and perhaps in other limited circumstances left open by the opinion.

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