Summary
The Supreme Court held that North Carolina courts could not exercise general personal jurisdiction over three foreign Goodyear subsidiaries in a wrongful-death action arising from a bus accident in France. The subsidiaries’ tires had reached North Carolina sporadically through intermediaries, but those contacts were insufficient to render the subsidiaries essentially at home in the State. The Court reversed the North Carolina Court of Appeals and held that stream-of-commerce contacts relevant to specific jurisdiction do not, by themselves, support general jurisdiction over unrelated claims.
Topics
Practice areas
Questions Presented
- Whether North Carolina could exercise general personal jurisdiction over foreign Goodyear subsidiaries for claims unrelated to any activity by the subsidiaries in North Carolina.
- Whether the subsidiaries' sporadic distribution of tires in North Carolina through intermediaries constituted the continuous and systematic affiliations necessary for general jurisdiction.
- Whether respondents could rely on a single-enterprise or unitary-business theory to attribute Goodyear USA's North Carolina contacts to its foreign subsidiaries.
Holdings
- A state may exercise general jurisdiction over a foreign corporation on unrelated claims only when the corporation's affiliations with the state are so continuous and systematic that it is fairly regarded as at home there. The foreign Goodyear subsidiaries were not at home in North Carolina and therefore were not subject to general jurisdiction.
- The flow of a manufacturer's products into the forum, including through intermediaries, may support specific jurisdiction when the product-related controversy arises in the forum, but it does not by itself establish general jurisdiction over unrelated claims.
- The Court did not reach the merits of respondents' single-enterprise or unitary-business theory because respondents forfeited it by failing to properly raise it below and in opposition to certiorari.
Key quotations
“A court may assert general jurisdiction over foreign (sister-state or foreign-country) corporations to hear any and all claims against them when their affiliations with the State are so “continuous and systematic” as to render them essentially at home in the forum State.” (564 U.S. at 919)
“The stream-of-commerce cases on which the North Carolina court relied relate to exercises of specific jurisdiction in products liability actions, in which a nonresident defendant, acting outside the forum, places in the stream of commerce a product that ultimately causes harm inside the forum.” (564 U.S. at 927)
“Measured against Helicopteros and Perkins, North Carolina is not a forum in which it would be permissible to subject petitioners to general jurisdiction.” (564 U.S. at 929)
Factual background
A bus accident outside Paris, France, killed two North Carolina residents. Their parents sued Goodyear USA and three foreign subsidiaries, alleging that a tire manufactured in Turkey was defective. The foreign subsidiaries were incorporated and operated in Luxembourg, Turkey, and France; they had no offices, employees, bank accounts, manufacturing, advertising, solicitation, or direct sales in North Carolina. A small percentage of their tires reached North Carolina through other Goodyear affiliates, but the type of tire allegedly involved in the accident was never distributed in North Carolina.
Procedural history
The Browns filed a wrongful-death action in the Superior Court of Onslow County, North Carolina, against Goodyear USA and three foreign subsidiaries after a bus accident in France allegedly caused by a defective tire manufactured abroad. The trial court denied the foreign subsidiaries' motions to dismiss. The North Carolina Court of Appeals affirmed, holding that the subsidiaries' tires had entered North Carolina through the stream of commerce and that this supported general jurisdiction; the North Carolina Supreme Court denied discretionary review. The United States Supreme Court reversed.
Remand instructions
The judgment of the North Carolina Court of Appeals was reversed. No further instructions are stated in the opinion.