News & Analysis as of

DaimlerChrysler v Bauman

Benesch

Far From Home: Supreme Court Expands General Jurisdiction for Out-of-State Defendants in Mallory v. Norfolk Southern Railway Co.

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When served with a summons and complaint for an out-of-state lawsuit, one of the first things a defendant is likely to ask is—can this court compel me to appear? Given that most transportation and logistics-related disputes...more

BakerHostetler

Corporate Consent Jurisdiction and the Supreme Court's Landmark Mallory Decision

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The Supreme Court has significantly expanded the possible grounds for personal jurisdiction against corporations, upholding Pennsylvania’s statute requiring foreign businesses registered in the Commonwealth to consent to...more

Holland & Knight LLP

U.S. Supreme Court Rejects Challenge to Registration Statute Requiring Consent to Jurisdiction

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In Mallory v. Norfolk Southern Railway Co., Robert Mallory (a Virginia resident) sued his former employer, Norfolk Southern (a Virginia-based railroad), over his alleged exposure to toxic chemicals while working for Norfolk...more

BCLP

Does the Supreme Court’s Extensive Personal Jurisdiction Jurisprudence Risk Going Off the Rails?

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The Supreme Court held that a corporation can be subject to personal jurisdiction in a state in which it has registered to do business—solely on that basis, and regardless of the extent of its operations in that state. ...more

Rivkin Radler LLP

U.S. Supreme Court Diminishes Daimler and Upends Aybar

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Plaintiffs’ counsel rejoice, defense counsel take note, and businesses beware. Daimler has been diminished and businesses are no longer only subject to general jurisdiction in states in which they are incorporated or...more

King & Spalding

Mallory Argument: Plaintiff Seeks To “Change The Jurisdictional Landscape”

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A Virginia resident sued a Virginia company headquartered in Virginia over events that occurred in Virginia. And he filed his lawsuit in…… Pennsylvania. The Court heard argument earlier this week in Mallory v. Norfolk...more

ArentFox Schiff

Shoe on the Other Foot? Why International Shoe May No Longer Be the Litmus Test for General Jurisdiction (Part One)

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In its upcoming October 2022 Term, the US Supreme Court is set to take up a challenge to how states are permitted to exercise jurisdiction over corporations. Mallory v. Norfolk Southern Railway Co., No. 21-1168, offers the...more

Zuckerman Spaeder LLP

Supreme Court Poised to Resolve Personal Jurisdiction-by-Consent Issue

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The Supreme Court is scheduled to hear argument on November 8 in Mallory v. Norfolk Southern Railway Co., 21-1168, and it appears ready to resolve a longstanding issue that has divided lower courts. That issue is whether it...more

Maron Marvel

Mr. Mallory Goes to Washington?

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It would not be surprising to find Mallory v. Norfolk Southern Railway Co. become mandatory class material across law schools in the future. The case presents a thought-provoking discussion of specific and general...more

Smith Anderson

Two Cases Involving Personal Vehicles Lead the Way on Personal Jurisdiction

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The law on specific personal jurisdiction is difficult to apply. This case - likely to be one of many such examples - shows why. Originally published on LAW.COM - March 15, 2022....more

Goulston & Storrs PC

General Jurisdiction Trend Grows With NY High Court's Ruling

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Since the U.S. Supreme Court's 2014 landmark decision in Daimler AG v. Bauman, courts around the country have been reexamining their prior holdings addressing whether a company consents to personal jurisdiction solely by...more

Smith Gambrell Russell

New York’s Highest Court Limits Jurisdiction Over Foreign Companies

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Foreign companies wishing to do business in New York are generally familiar with the requirement that, under New York Business Corporation Law (the BCL), a foreign corporation must obtain authorization to do so. If such a...more

King & Spalding

District of New Jersey Jettisons Third Circuit’s Causation Requirement for Personal Jurisdiction in Wake of Supreme Court’s Ford...

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On May 11, 2021, Judge Kevin McNulty of the District of New Jersey issued an order applying the Supreme Court’s recent personal jurisdiction decision in Ford Motor Co. v. Montana Eighth Judicial District Court, 141 S. Ct....more

Pillsbury Winthrop Shaw Pittman LLP

Affirming Dismissal of AirAsia Lawsuit, D.C. Circuit Court Overrules Prior Decisions Allowing Personal Jurisdiction Based on...

In affirming the dismissal of a lawsuit against Pillsbury’s client, AirAsia, the D.C. Circuit overruled its prior precedent that a company’s website could be sufficient to support general jurisdiction. A company’s internet...more

Smith Anderson

Personal Jurisdiction Does Restrict Where a Corporation Can Be Sued

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A plaintiff bringing a lawsuit will often want to file close to home, for various strategic and logistical reasons. The appeal of filing at home has perhaps never been stronger, as COVID-19 casts uncertainty on travel plans...more

Cozen O'Connor

Supreme Court to Hear Specific Personal Jurisdiction Product Cases That Caused Harm in Forum States

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Recently, the U.S. Supreme Court agreed to hear a manufacturer’s challenge to two state supreme court decisions (Minnesota and Montana) that allowed plaintiffs to bring product defect suits in states where the manufacturer...more

Nutter McClennen & Fish LLP

Communications were Insufficient Contacts to Exercise Personal Jurisdiction Over Out-of-State Auditors

In B. Bullen et al. v. CohnReznick LLP, investors in a defunct hedge fund sued CohnReznick, the outside auditor and accountant of the fund. The investors claimed, among other things, that CohnReznick had conspired with the...more

Chartwell Law

Is Death By Registration in Pennsylvania Still the Norm?

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With certain jurisdictions within Pennsylvania being considered highly favorable to plaintiffs, claimants and their counsel often go to great lengths to have suit brought in Pennsylvania.  Any long-time litigation...more

A&O Shearman

Second Circuit Affirms Dismissal Of Claims, Finding No Personal Jurisdiction Where Defendants Were Not "At Home" In The Forum And...

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On February 9, 2018, the United States Court of Appeals for the Second Circuit affirmed the dismissal of aiding and abetting claims against UBS AG, AIA LLC, and their affiliated entities and individuals. SPV Osus Ltd. v. UBS...more

King & Spalding

New York Courts Continue to Reject Consent-By-Registration Theory of Personal Jurisdiction Post-Daimler

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On October 18, 2017, the U.S. District Court for the Southern District of New York (S.D.N.Y.) decided Sae Han Sheet Co. v. Eastman Chemical Corp., the latest in a series of cases to examine whether an out-of-state corporation...more

Miles & Stockbridge P.C.

Personal Jurisdiction Defense Gaining Traction in Mass Tort Litigation

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For the past several years the United States Supreme Court has sought to clarify the proper exercise of specific personal jurisdiction over foreign corporate defendants. This issue is particularly applicable in mass tort...more

Rumberger | Kirk

SCOTUS Limits Jurisdictions Where Corporations Can Be Sued

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With its recent opinion in BNSF Railway Co. v. Tyrrell, the United States Supreme Court reaffirmed the strong position that it took in Daimler AG v. Bauman with respect to general jurisdiction, leaving no doubt that a...more

Miles & Stockbridge P.C.

U.S. Supreme Court Clarifies Constitutional Limits on Specific Jurisdiction Over Foreign Defendants…Again

Since 2011, the U.S. Supreme Court has continued to roll back the expansion of personal jurisdiction by lower courts and has set more limitations on where a plaintiff can sue corporate defendants. We have watched this unfold...more

Cozen O'Connor

The Supreme Court Gets “Specific” on Jurisdiction

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For the second time in the last three years, the U.S. Supreme Court has addressed the constitutional limits of a court’s ability to exercise jurisdiction over a defendant. The 14th Amendment limits the personal jurisdiction...more

Foley & Lardner LLP

Back to Basics: A Review of Recent SCOTUS Personal Jurisdiction Jurisprudence

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As its term drew to a close, the Supreme Court handed down its latest decision on personal jurisdiction in a case entitled Bristol-Myers Squibb Co. v. Superior Court of Cal., San Francisco Cty. Over the last six years, the...more

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