Daimler AG v. Bauman

571 U.S. 117, 134 S. Ct. 746, 187 L. Ed. 2d 624 · Supreme Court of the United States · 2014

Civil Procedure Assigned in 20 casebooks

Case brief summary

Rule

A court can only hear any and all lawsuits against a company (not just ones tied to that location) if the company is essentially 'at home' there, usually where it is incorporated or has its main offices.

Facts

Argentine residents sued Daimler, a German car company, in a California court for human rights abuses by its Argentine subsidiary during Argentina's 'Dirty War,' claiming California had power over Daimler because a separate Daimler subsidiary sold cars there.

Procedural history

A federal district court dismissed the case for lack of jurisdiction, but a federal appeals court reversed, ruling that the California subsidiary's sales activities could be treated as Daimler's own contacts for jurisdiction purposes.

Issue

Does the Constitution's fairness guarantee allow a California court to hear this lawsuit against Daimler for conduct that happened entirely in Argentina, based only on a subsidiary's sales activity in California?

Holding

No, Daimler is not 'at home' in California, so California courts cannot hear this lawsuit against it.

Reasoning

Even if the subsidiary's California sales counted as Daimler's own, Daimler is based in Germany, not California. Treating normal business activity as enough would let companies be sued almost anywhere, which is unfair.

Opinions

Majority (Ginsburg): A company can only be sued on any type of claim in a place where it is truly 'at home,' and Daimler was not at home in California so the case could not proceed there.

Concurrences (Sotomayor): Agreed the case should be thrown out but said the Court should have used a simpler fairness test instead of creating a new 'at home' comparison rule.

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What underlying conduct gave rise to the plaintiffs' claims against Daimler?

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