Master Supreme Court limits state courts’ general jurisdiction over foreign corporations to forums where they are essentially at home, rejecting stream-of-commerce as a basis for all-purpose jurisdiction. with this comprehensive case brief.
Goodyear v. Brown is a landmark United States Supreme Court decision that modernized and narrowed the doctrine of general (all-purpose) personal jurisdiction over corporations. Building on International Shoe’s minimum contacts framework and clarifying Helicopteros’ continuous and systematic language, the Court held that a corporation is subject to general jurisdiction only where its affiliations are so continuous and systematic as to render it essentially at home in the forum state. The paradigmatic forums are the corporation’s place of incorporation and principal place of business, with only exceptional cases outside those anchors.
The decision decisively rejected attempts to transform occasional or attenuated product sales in a forum—arriving via the stream of commerce—into grounds for general jurisdiction. Goodyear thus draws a sharp doctrinal line between case-linked specific jurisdiction and the much narrower category of general jurisdiction. The case set the stage for Daimler AG v. Bauman (2014), which further cemented the “at home” standard and reshaped nationwide strategies for suing corporate defendants.
564 U.S. 915 (2011) (U.S. Supreme Court)
North Carolina residents brought wrongful-death actions in North Carolina state court after two North Carolina teenagers were killed in a bus accident outside Paris, France. Plaintiffs alleged the accident was caused by a defective tire manufactured in Turkey by a foreign subsidiary of Goodyear USA. They sued Goodyear USA and three of its foreign subsidiaries (incorporated and operating in Turkey, France, and Luxembourg). The foreign defendants had no place of incorporation or principal place of business in North Carolina, were not registered to do business there, maintained no offices, property, bank accounts, or employees in the state, and did not design, advertise, or specifically direct sales to North Carolina. A relatively small number of tires made by the foreign subsidiaries, however, reached North Carolina through the stream of commerce via intermediaries. The tire involved in the accident was manufactured and sold abroad and never entered North Carolina. The North Carolina trial court exercised general jurisdiction over the foreign subsidiaries, and the North Carolina Court of Appeals affirmed, concluding that their products’ flow into the state constituted continuous and systematic contacts sufficient for general jurisdiction. The foreign subsidiaries sought and obtained certiorari.
Whether a state court may exercise general personal jurisdiction over foreign corporate subsidiaries based solely on the fact that a small number of their products entered the forum state through the stream of commerce, where the accident occurred abroad and the subsidiaries are neither incorporated nor headquartered in the forum.
General (all-purpose) jurisdiction over a corporation exists only where the corporation’s affiliations with the forum are so continuous and systematic as to render it essentially at home in the forum state. The paradigm forums are the place of incorporation and the principal place of business; only in an exceptional case may a corporation be at home in another forum. The stream-of-commerce principle—focused on case-linked, suit-related contacts—does not establish general jurisdiction over claims unrelated to the forum.
No. The exercise of general jurisdiction by North Carolina courts over the foreign subsidiaries violated due process. The subsidiaries’ sporadic product sales in North Carolina, via intermediaries, did not render them essentially at home in the state.
The Court, per Justice Ginsburg, distinguished specific from general jurisdiction. Specific jurisdiction depends on an affiliation between the forum and the underlying controversy—i.e., the suit must arise out of or relate to the defendant’s forum contacts. In contrast, general jurisdiction authorizes suit on any claim, even those unrelated to the forum, and thus demands a substantially higher showing: the defendant must be essentially at home in the forum. The North Carolina Court of Appeals erred by importing stream-of-commerce reasoning—pertinent to specific jurisdiction—into the general jurisdiction analysis. The foreign subsidiaries did not have offices, property, agents, or employees in North Carolina, were not registered to do business there, and did not design or market their products specifically for the state. The relatively small number of their tires that reached North Carolina through the stream of commerce was too attenuated to make them at home there, particularly where the accident occurred in France and the allegedly defective tire neither was sold nor used in North Carolina. The Court clarified that Helicopteros’ “continuous and systematic” phrasing must be understood in light of International Shoe and later developments: it is not a mere tally of in-state contacts, but a qualitative inquiry into whether the defendant is essentially at home. The paradigmatic forums are the company’s place of incorporation and principal place of business; while an exceptional case may justify general jurisdiction elsewhere (e.g., Perkins, where a company’s wartime relocation concentrated corporate operations in Ohio), the record here showed nothing comparable. Nor could contacts of Goodyear USA be attributed to its foreign subsidiaries absent a showing that corporate separateness should be disregarded. Because the asserted contacts did not meet the exacting “at home” standard, general jurisdiction was improper.
Goodyear is a foundational case in modern personal jurisdiction doctrine, sharply narrowing general jurisdiction and clarifying that the stream of commerce cannot bootstrap unrelated claims into an all-purpose forum. It introduced and operationalized the “essentially at home” formulation for corporations, later reinforced in Daimler AG v. Bauman. For law students, the case is a touchstone for exam analysis: (1) separate specific from general jurisdiction; (2) identify paradigmatic at-home forums (incorporation and principal place of business); (3) consider the rare “exceptional case” like Perkins; and (4) reject reliance on scattered sales or distribution chains for general jurisdiction when the claim does not arise from forum contacts.
Specific jurisdiction is case-linked: the claim must arise out of or relate to the defendant’s forum contacts. General jurisdiction is all-purpose: the defendant may be sued on any claim, but only if its affiliations with the forum render it essentially at home there. Goodyear emphasizes that the evidentiary threshold for general jurisdiction is much higher.
Stream-of-commerce contacts, even if purposeful for specific jurisdiction, concerned the distribution of products and are tied to whether the claim arises from those contacts. In Goodyear, the suit had no connection to North Carolina: the accident occurred in France, and the tire at issue never entered North Carolina. Thus, sporadic product flow into the state could not justify all-purpose jurisdiction.
A corporation is essentially at home in its place of incorporation and principal place of business—these are the paradigmatic forums. Only in exceptional circumstances, where the corporation’s operations are so concentrated in another forum as to approximate a home (as in Perkins), might general jurisdiction exist elsewhere.
No. Specific jurisdiction requires suit-related contacts with the forum. The relevant conduct and injury occurred in France, and the allegedly defective tire was manufactured and sold abroad and never reached North Carolina. There was no claim-related nexus to the forum.
Daimler built on Goodyear’s ‘at home’ standard, holding that general jurisdiction typically lies only in a corporation’s place of incorporation and principal place of business, with truly exceptional cases as the narrow exception. Daimler further rejected attempts to impute a subsidiary’s forum contacts to a foreign parent to create general jurisdiction.
Goodyear v. Brown tightened the constitutional boundaries of general jurisdiction, making clear that corporations are not subject to all-purpose jurisdiction wherever their products happen to be sold. Instead, general jurisdiction is ordinarily limited to the corporation’s formal homes—place of incorporation and principal place of business—ensuring predictability and fairness in the forum-selection analysis.
For practitioners and students, the case underscores the importance of carefully distinguishing claim-linked contacts (specific jurisdiction) from the rare circumstances justifying all-purpose jurisdiction. Goodyear’s ‘essentially at home’ test now anchors general jurisdiction analysis and remains central to personal jurisdiction strategy and doctrine.