Master Supreme Court narrows corporate general jurisdiction to forums where a corporation is essentially at home. with this comprehensive case brief.
Daimler AG v. Bauman is the Supreme Court’s modern lodestar on general (all-purpose) personal jurisdiction over corporations. Building on Goodyear Dunlop Tires v. Brown, the Court held that a corporation is subject to general jurisdiction only where it is essentially at home—paradigmatically its place of incorporation and principal place of business—with only truly exceptional facts permitting otherwise. This decision rejects the earlier practice of treating substantial, continuous, and systematic in-state business as sufficient for general jurisdiction.
The case transformed forum-selection strategy in transnational litigation, product liability, and nationwide class actions. It curtails forum shopping by clarifying that even extensive in-state sales, marketing, and facilities usually do not make a multinational corporation at home, and it sharply limits the imputation of a subsidiary’s forum contacts to a foreign parent. Daimler is now the primary checkpoint in any personal-jurisdiction analysis involving corporate defendants and general jurisdiction.
Daimler AG v. Bauman, 571 U.S. 117 (2014)
Argentine plaintiffs sued Daimler AG, a German corporation with its principal place of business in Germany, in California state court (removed to federal court) alleging that Mercedes-Benz Argentina, Daimler’s Argentine subsidiary, collaborated with state security forces during Argentina’s Dirty War to detain, torture, and kill workers. The alleged conduct occurred entirely in Argentina, and the plaintiffs were foreign residents. Plaintiffs sought to establish general jurisdiction over Daimler in California based on the California contacts of Mercedes-Benz USA, LLC (MBUSA), a U.S. subsidiary that distributes Daimler-manufactured vehicles nationwide and operates multiple facilities, dealers, and substantial sales in California. The Ninth Circuit held that MBUSA was subject to general jurisdiction in California and that MBUSA’s contacts could be imputed to Daimler under an agency theory, thereby allowing California courts to exercise general jurisdiction over Daimler. The Supreme Court granted certiorari.
Does the Due Process Clause permit California courts to exercise general (all-purpose) personal jurisdiction over Daimler AG, a German company, in a suit brought by foreign plaintiffs for foreign conduct, based solely on the California contacts of Daimler’s U.S. subsidiary imputed to Daimler?
Under the Fourteenth Amendment’s Due Process Clause, a state court may exercise general jurisdiction over a corporate defendant only where the corporation is fairly regarded as at home in the forum. The paradigm forums are the place of incorporation and the principal place of business. In an exceptional case, a corporation’s operations in another state may be so substantial relative to its overall activities as to render it at home there. Mere continuous and systematic business in the state—even extensive sales, facilities, or the in-state contacts of a subsidiary—does not, without more, render the parent corporation at home. Attribution of a subsidiary’s contacts to a parent requires more than a broad agency theory; typically, only alter-ego or veil-piercing circumstances will suffice.
No. California courts may not exercise general jurisdiction over Daimler AG. Even assuming MBUSA’s California contacts could be imputed to Daimler, those contacts do not render Daimler essentially at home in California.
The Court, per Justice Ginsburg, emphasized that general jurisdiction permits a court to hear any and all claims against a defendant and therefore must be confined to forums where the defendant is essentially at home. For corporations, that ordinarily means the place of incorporation and principal place of business. The Court reaffirmed Goodyear’s at-home framework and clarified that International Shoe’s reference to continuous and systematic business does not supply an independent test for general jurisdiction. Applying that standard, the Court assumed without deciding that MBUSA’s California contacts were attributable to Daimler. Even so, Daimler’s affiliations with California were insufficient. Daimler is incorporated and headquartered in Germany, and its California-related activities represented only a slice of its vast, global operations. A corporation that operates in many places cannot be deemed at home in all of them; otherwise, most large multinationals would be subject to general jurisdiction everywhere they do significant business, a result inconsistent with due process and international comity concerns. The Court contrasted the facts with the exceptional case in Perkins, where war-time displacement effectively made Ohio the corporation’s principal place of business. The Court further rejected the Ninth Circuit’s expansive agency theory, which would allow imputation of a subsidiary’s forum contacts whenever the subsidiary performs services important to the parent. That approach would subject parent corporations to general jurisdiction in every state where an in-state subsidiary engages in significant business. Such an approach would make general jurisdiction effectively universal for multinationals and collapse the distinction between general and specific jurisdiction. Because Daimler was not at home in California, the due process inquiry ended; the Court did not proceed to weigh reasonableness factors. Justice Sotomayor concurred in the judgment, agreeing that jurisdiction was improper but criticizing the majority’s reformulation as unnecessarily rigid and proposing to resolve the case on reasonableness grounds.
Daimler is the cornerstone of modern general jurisdiction. It instructs that general jurisdiction over a corporation lies almost exclusively in its state of incorporation and principal place of business, with only rare exceptions. The decision curbs forum shopping, limits the imputation of subsidiary contacts to foreign parents absent alter-ego circumstances, and channels most litigation into specific jurisdiction or into the defendant’s true home forums. It has been repeatedly applied to reject general jurisdiction based on substantial in-state sales or widespread U.S. operations (e.g., BNSF Railway v. Tyrrell). For law students, Daimler reshapes personal-jurisdiction analysis: start with the at-home inquiry for general jurisdiction, distinguish sharply from specific jurisdiction, and treat agency-based imputation with skepticism.
At home identifies the limited forums where a corporation can be sued on any claim, regardless of where the claim arose. The paradigms are the corporation’s place of incorporation and principal place of business. Only in rare, exceptional circumstances—where in-state operations are so substantial relative to the company’s global activities that the forum effectively functions as a surrogate home—will another forum qualify.
No. Daimler rejects broad agency-based imputation for general jurisdiction. A parent’s amenability to all-purpose jurisdiction cannot ordinarily rest on a subsidiary’s in-state activities. Imputation is limited to exceptional circumstances, such as alter-ego or veil-piercing situations where the subsidiary is not meaningfully separate from the parent.
Daimler concerns general jurisdiction and leaves specific jurisdiction intact. It channels most cases to specific jurisdiction, which requires that the plaintiff’s claim arise out of or relate to the defendant’s forum contacts and that the exercise of jurisdiction is consistent with fair play and substantial justice. Large in-state sales or a distribution network may support specific jurisdiction in cases linked to those contacts, but not general jurisdiction for unrelated claims.
Perkins v. Benguet Mining is the classic example: wartime conditions displaced the company’s operations to Ohio, making Ohio the practical headquarters. That level of forum-centered operations, relative to the company’s total activities, is required to find an exceptional home forum. Routine extensive sales, multiple facilities, or a large workforce in a state generally do not suffice.
Daimler addresses contacts-based general jurisdiction, not consent. Some states assert general jurisdiction through corporate registration and appointment of an agent for service. Whether such statutes amount to valid consent is a separate question. Subsequent cases indicate that express consent-by-registration can be constitutionally permissible depending on state law and other constitutional constraints, but Daimler’s at-home test still governs when consent is absent.
Daimler AG v. Bauman recast general jurisdiction into a narrow doctrine tethered to where a corporation is truly at home. By rejecting expansive agency theories and the notion that extensive in-state business alone confers all-purpose jurisdiction, the Court preserved the distinction between general and specific jurisdiction and realigned personal-jurisdiction doctrine with due process and international comity.
For litigators and students, Daimler is a threshold checkpoint: ask first whether the defendant is at home in the forum; if not, pivot to specific jurisdiction or sue in a home forum. Its disciplined framework now governs corporate jurisdictional strategy across transnational human-rights claims, nationwide product cases, and multistate commercial disputes.