Daimler AG v. Bauman
134 S. Ct. 746
| SCOTUS | 2014Background
- Twenty-two Argentine residents sue DaimlerChrysler AG in California federal court alleging MB Argentina collaborated with Argentinian security forces during 1976–1983 Dirty War to kidnap, detain, torture, and kill workers; claims include ATS and TVPA, plus California and Argentina law.
- Jurisdiction premised on the California contacts of MBUSA, a Daimler subsidiary; MBUSA distributes Daimler vehicles nationwide including California.
- District Court dismissed for lack of personal jurisdiction; Ninth Circuit held MBUSA was Daimler’s agent for purposes of general jurisdiction and thus Daimler could be sued in California.
- Daimler petitioned for certiorari; the Court granted to decide if due process allows general jurisdiction over a foreign parent based on a foreign subsidiary’s in-forum activities.
- The Court held Daimler is not amenable to general jurisdiction in California for Argentina-rooted claims arising abroad; MBUSA’s California presence does not render Daimler at home in California.
- Justice Sotomayor concurred in the judgment but disagreed with the majority’s reasoning and explained a different path rooted in due process and reasonableness.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether California can exercise general jurisdiction over Daimler based on MBUSA’s California contacts | Bauman argues MBUSA’s CA contacts render Daimler at home in CA. | Daimler argues no general jurisdiction; MBUSA’s contacts do not make Daimler at home in CA. | No general jurisdiction; Daimler not at home in California. |
| Whether MBUSA’s CA contacts can be imputed to Daimler to establish general jurisdiction | MBUSA acts as Daimler’s agent; its CA contacts should be attributable to Daimler. | Agency alone cannot support general jurisdiction; no umbrella attribution. | Agency attribution cannot sustain general jurisdiction; Daimler not at home. |
| Whether Daimler’s general jurisdiction is warranted under the Goodyear framework | Daimler’s nationwide operations should make it subject to general jurisdiction in CA. | General jurisdiction requires the foreign corporation to be at home in the forum; not satisfied here. | General jurisdiction not warranted; not at home in California. |
| Whether the transnational context and comity considerations affect the due process analysis | Expansive jurisdiction would promote accountability for international human rights violations. | Overbroad general jurisdiction risks undermining international comity and predictability. | Due process bars general jurisdiction; transnational context supports limiting jurisdiction. |
Key Cases Cited
- Goodyear Dunlop Tires Operations, S. A. v. Brown, 564 U. S. _ (2011) (defined general vs. specific jurisdiction; ‘at home’ standard for general jurisdiction)
- International Shoe Co. v. Washington, 326 U. S. 310 (1945) (established minimum contacts and fair play for jurisdiction)
- Perkins v. Benguet Consol. Mining Co., 342 U. S. 437 (1952) (example of general jurisdiction based on substantial ties to forum)
- Helicopteros Nacionales de Colombia, S. A. v. Hall, 466 U. S. 408 (1984) (limited in-state contacts not enough for general jurisdiction)
- Pennoyer v. Neff, 95 U. S. 714 (1878) (territorial limits of a forum; Pennoyer framework)
- Shaffer v. Heitner, 433 U. S. 186 (1977) (cohesion of territorial and caselaw-based jurisdiction)
- Kiobel v. Royal Dutch Petroleum Co., 569 U. S. _ (2013) (presumption against extraterritorial ATS application)
- Mohamad v. Palestinian Authority, 566 U. S. _ (2012) (TVPA limitations in extraterritorial context)