Daimler AG v. Bauman

Residents of Argentina sued Daimler, a German company, in a California federal district court, alleging that Mercedes-Benz Argentina, a Daimler subsidiary, collaborated with state security forces during Argentina’s 1976–1983 “Dirty War” to kidnap, detain, torture, and kill MB Argentina workers, related to the plaintiffs. They asserted claims under the Alien Tort Statute and the Torture Victim Protection Act of 1991, and under California and Argentina law. Personal jurisdiction was predicated on the California contacts of Mercedes-Benz USA (MBUSA), another Daimler subsidiary, incorporated in Delaware with its principal place of business in New Jersey. MBUSA distributes Daimler-manufactured vehicles to independent U.S. dealerships, including some in California. The district court dismissed. The Ninth Circuit reversed, holding that MBUSA, which it assumed to fall within the California courts’ all-purpose jurisdiction, was Daimler’s “agent” for jurisdictional purposes. The Supreme Court reversed. Daimler is not amenable to suit in California for injuries allegedly caused by MB Argentina outside the U.S. California’s long-arm statute allows the exercise of personal jurisdiction to the full extent permissible under the U. S. Constitution. Even if California is home to MBUSA, Daimler’s affiliations with California are not sufficient to subject it to the general jurisdiction of that State’s courts. The proper inquiry is whether a foreign corporation’s “affiliations with the State are so ‘continuous and systematic’ as to render [it] essentially at home in the forum State.” Neither Daimler nor MBUSA is incorporated in California; neither has its principal place of business there. If Daimler’s California activities sufficed to allow adjudication of this case in California, the same global reach would presumably be available in every other state in which MBUSA’s sales are sizable. View "Daimler AG v. Bauman" on Justia Law