Goodyear Dunlop Tires Operations, S. A. v. Brown
131 S. Ct. 2846
| SCOTUS | 2011Background
- North Carolina wrongful-death suit against Goodyear USA and three foreign Goodyear subsidiaries for a bus crash outside Paris.
- Subsidiaries incorporated in Luxembourg, Turkey, and France manufacture tires for European/Asian markets; tires differ from US-market tires.
- Goodyear USA had NC business presence; subsidiaries had no NC registrations, offices, employees, bank accounts, or direct sales in NC.
- Only a small percentage of petitioners’ tires reached NC via Goodyear USA affiliates, mostly distributed for niche buyers.
- NC Court of Appeals held general jurisdiction existed based on streams of commerce; petitioners argued lack of continuous/systematic ties to NC.
- Supreme Court reversed, holding no general jurisdiction over claims unrelated to in-state activities; emphasized distinction between general and specific jurisdiction and limits of stream-of-commerce as a basis for general jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether NC has general jurisdiction over foreign subsidiaries for claims unrelated to forum activities. | Brown argues subsidiaries are at home via continuous activities. | Goodyear subsidiaries lack continuous/systematic ties to NC. | No general jurisdiction over unrelated claims. |
| Whether stream-of-commerce supports general jurisdiction over foreign subsidiaries. | Stream of commerce shows forum connection. | Flow alone cannot establish general jurisdiction for unrelated claims. | Stream of commerce insufficient for general jurisdiction. |
| Whether the subsidiaries can be treated as a unitary business to justify jurisdiction over Goodyear. | Petitioners form integrated unit with parent. | Subsidiaries are separate entities; unitary treatment not urged. | Forfeited; not addressed. |
| Distinction between general and specific jurisdiction applied to the facts. | Some ties to NC support general jurisdiction. | Only specific jurisdiction may apply for in-forum events. | General jurisdiction not warranted; events occurred outside NC. |
| Whether the NC long-arm statute changes the general jurisdiction analysis. | Statutory ties could broaden jurisdiction. | Statute cannot override due process limits for unrelated claims. | Statute does not authorize general jurisdiction here. |
Key Cases Cited
- International Shoe Co. v. Washington, 326 U.S. 310 (1945) (established minimum contacts and fair play standard for jurisdiction)
- World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (1980) (purposeful availment; stream of commerce insufficient for general jurisdiction)
- Perkins v. Benguet Consol. Mining Co., 342 U.S. 437 (1952) (example of general jurisdiction based on at-home contacts)
- Helicopteros Nacionales de Colombia v. Hall, 466 U.S. 408 (1984) (general jurisdiction requires more than occasional purchases in forum)
- Asahi Metal Industry Co. v. Superior Court, 480 U.S. 102 (1987) (addressed limits of stream-of-commerce in jurisdictional analysis)
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985) (ongoing forum connections justify jurisdiction in contract disputes)