Cooper Tire & Rubber Company v. McCall

Summary

The Supreme Court of Georgia considered whether Georgia courts may exercise general personal jurisdiction over an out-of-state corporation that is authorized to transact business in Georgia. The court reaffirmed its holding in Allstate Insurance Co. v. Klein, concluding that Georgia’s statutory scheme treats such a corporation as a resident and that consent-by-registration jurisdiction remains constitutionally permissible under Pennsylvania Fire Insurance Co. v. Gold Issue Mining & Milling Co. The court affirmed the Court of Appeals’ decision subjecting Cooper Tire to general jurisdiction in Georgia.

Holdings

1. Klein's holding that an out-of-state corporation's registration and authorization to transact business in Georgia constitutes consent to general personal jurisdiction does not violate federal due process because Pennsylvania Fire Insurance Co. of Philadelphia v. Gold Issue Mining & Milling Co. remains binding and has not been overruled.
2. Klein's statutory-construction holding should not be overruled.
3. Because Cooper Tire was registered and authorized to transact business in Georgia, it is subject to the general jurisdiction of Georgia courts under Klein, although it is not subject to specific jurisdiction under the Long Arm Statute.

Questions Presented

1. Whether Georgia may exercise general personal jurisdiction over an out-of-state corporation that is authorized to transact business in Georgia under the rule announced in Allstate Insurance Co. v. Klein.
2. Whether Klein's general-jurisdiction holding violates the Due Process Clause of the Fourteenth Amendment in light of modern United States Supreme Court general-jurisdiction decisions.
3. Whether Klein should be overruled as a matter of statutory interpretation and stare decisis.

Disposition

affirmed