Goodyear Dunlop Tires Operations, S.A. v. Brown
Citation: 564 U.S. 915 (2011)
Facts
Two North Carolina boys were killed in a bus accident outside Paris, France. Their parents sued foreign subsidiaries of Goodyear USA (including Turkish, French, and Luxembourgish entities) in North Carolina state court, claiming defective tires. The foreign subsidiaries had no direct operations in North Carolina; a small percentage of their tires were distributed there through stream of commerce.
Issue
Does a foreign corporation’s placement of products into the stream of commerce that reach the forum state suffice to establish general (all-purpose) personal jurisdiction over the corporation?
Holding
No. The Supreme Court unanimously held that the North Carolina courts lacked general jurisdiction over the foreign Goodyear subsidiaries. General jurisdiction requires that the corporation be “at home” in the forum — essentially, incorporated there or having its principal place of business there. Sporadic product sales through the stream of commerce are insufficient.
Rule
General (all-purpose) jurisdiction over a corporation exists only where the corporation is “at home” — paradigmatically, its place of incorporation and principal place of business. Contacts that fall short of making the corporation “at home” in the forum cannot support general jurisdiction, even if they are substantial.
Significance
Goodyear, decided the same day as J. McIntyre Machinery v. Nicastro, established the modern “at home” test for general jurisdiction over corporations, which was then further refined in Daimler AG v. Bauman. Together these cases dramatically narrowed the reach of general jurisdiction.