Perkins v. Benguet Consolidated Mining Co.
Citation
342 U.S. 437 (1952)
Facts
Benguet Consolidated Mining Co. was a Philippine corporation that operated gold and silver mines in the Philippines. During the Japanese occupation in WWII, the company was forced to suspend operations and its president relocated to Ohio, conducting all corporate business from there — holding directors’ meetings, keeping corporate records, maintaining bank accounts, and managing the company’s affairs. An Ohio plaintiff sued Benguet in Ohio for claims entirely unrelated to any Ohio activity.
Issue
May an Ohio court exercise general jurisdiction over a foreign corporation whose president has relocated corporate management and operations to Ohio, even for claims unrelated to Ohio activities?
Holding
Yes. The Supreme Court held that Ohio could exercise general jurisdiction over Benguet based on its substantial, continuous, and systematic contacts with Ohio — the company’s entire nerve center had effectively moved there.
Rule / Doctrine
A corporation may be subject to general jurisdiction (jurisdiction over any claim, regardless of connection to the forum) when its contacts with the forum are so substantial, continuous, and systematic that the state effectively functions as the corporation’s principal place of business or domicile. This is the paradigmatic case of a corporation that is “at home” in a state other than its state of incorporation.
Significance
Perkins is the Supreme Court’s clearest pre-Goodyear/Daimler example of general jurisdiction upheld. It remains good law after Daimler AG v. Bauman (2014) as an exceptional case — one where the foreign corporation’s entire operational center had physically relocated to Ohio. Courts cite Perkins as the benchmark for what extraordinary circumstances can make a corporation “at home” outside its state of incorporation.