Daimler AG v. Bauman
The Court ruled that a German car manufacturer could not be sued in California courts over human-rights abuses its Argentine subsidiary allegedly committed in Argentina, even though the manufacturer's separate U.S. sales subsidiary did substantial business in California.
The decision tightens the rules for when a company can be sued anywhere on any claim, holding that a corporation is subject to this broad 'general jurisdiction' only in places where it is essentially 'at home,' typically where it is incorporated or headquartered.
“Exercises of personal jurisdiction so exorbitant, we hold, are barred by due process constraints on the assertion of adjudicatory authority.”
The majority explains why letting California hear a case with no connection to the state goes too far.
How it got here: A federal trial court dismissed the suit for lack of jurisdiction; the Ninth Circuit reversed, finding jurisdiction proper; Daimler asked the Supreme Court to review that ruling.
The Case in Depth
What happened
Twenty-two Argentine residents sued Daimler, a German car manufacturer, alleging its Argentine subsidiary, Mercedes-Benz Argentina, worked with government security forces during Argentina's 1976-1983 "Dirty War" to kidnap, torture, and kill workers, including the plaintiffs or their relatives. None of the alleged conduct occurred in the United States. The plaintiffs tried to sue Daimler in California based on the California business activities of a separate Daimler subsidiary, Mercedes-Benz USA, which distributes vehicles nationwide.
The question before the Court
Could Argentine victims of the country's "Dirty War" sue a German car company in a California court, based only on the California business of the company's U.S. sales subsidiary?
The Court's answer
No — the Court ruled that Daimler could not be sued in California because a corporation is subject to this kind of broad, all-purpose jurisdiction only where it is essentially "at home," which ordinarily means its place of incorporation or its principal place of business. Daimler is incorporated and headquartered in Germany, not California, so it wasn't "at home" there even though its separate sales subsidiary did substantial California business.
The Court explained that treating a company as suable anywhere it has a busy subsidiary would let plaintiffs drag foreign corporations into court over conduct with no connection to that state, undermining the predictability companies need to know where they can be sued. Because the underlying kidnappings and killings happened entirely in Argentina and involved only foreign parties, California had no legitimate claim to hear this dispute.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
The ruling makes it much harder to sue large multinational corporations in U.S. courts over conduct that happened entirely overseas, just because the company sells products or has a subsidiary here. Businesses gain more predictability about where they can be dragged into court, while plaintiffs injured abroad — including in human-rights cases — lose a potential U.S. forum unless the harm or the company's true home is tied to that state.
What changes now
The Ninth Circuit's judgment allowing the suit to proceed in California is reversed, meaning the Argentine plaintiffs cannot pursue their claims against Daimler in a California court on this theory. This is a final decision on the jurisdictional question, though it does not resolve whether the plaintiffs could sue Daimler somewhere else, such as Germany or Argentina. The ruling also reshapes how lower courts nationwide analyze general jurisdiction over corporations going forward.
What this does not decide
The Court did not decide whether an agency theory could ever justify attributing a subsidiary's contacts to its parent for jurisdictional purposes, nor whether the reasonableness of exercising jurisdiction (separate from the "at home" test) matters in general-jurisdiction cases — issues Justice Sotomayor argued the majority did not need to reach.
Concurrences and dissents
Concurrence — Justice Sotomayor
Justice Sotomayor agreed Daimler should not be sued in California but objected to the majority's reasoning. She argued the Court wrongly decided the case on a ground never raised below or in the certiorari petition, and that its focus on comparing Daimler's California contacts to its worldwide operations abandons the traditional test asking only whether in-state contacts are substantial. She would instead have held jurisdiction unreasonable given that Argentine plaintiffs were suing a German company over foreign conduct, without disturbing the settled contacts test.
How the Court got there
The legal reasoning, step by step
- The Court distinguished two kinds of personal jurisdiction: 'specific jurisdiction,' which lets a court hear a case arising from the defendant's own contacts with that state, and 'general jurisdiction,' which lets a court hear any claim against a defendant regardless of where the underlying conduct occurred, so long as the defendant is essentially 'at home' there.
- Relying on its recent decision in Goodyear Dunlop Tires Operations v. Brown, the Court held that the paradigm places a corporation is 'at home' are its place of incorporation and its principal place of business, with only rare exceptions for a truly exceptional case.
- The Court rejected the Ninth Circuit's approach of treating the sales subsidiary's California activities as important enough to Daimler that Daimler would perform them itself if the subsidiary vanished, reasoning that this logic would make almost any parent company answerable everywhere a subsidiary operates.
- Even assuming the sales subsidiary's California contacts could be attributed to Daimler, the Court held those contacts still would not make Daimler 'at home' in California once measured against Daimler's entire nationwide and worldwide operations, since neither company was incorporated or headquartered there.
- The Court noted that recent decisions had already undercut the plaintiffs' claims under the Alien Tort Statute and the Torture Victim Protection Act, and that treating California as an all-purpose forum for a dispute with no U.S. connection would also strain relations with other countries wary of overly broad American jurisdiction.
Doctrinal impact
Cases affected by this decision
Reaffirms Goodyear Dunlop Tires Operations, S. A. v. Brown (564 U. S. ___)
Reaffirms and builds on Goodyear's rule that general jurisdiction requires a corporation to be essentially 'at home' in the state.
Reaffirms International Shoe Co. v. Washington (326 U. S. 310)
Relies on International Shoe's original distinction between case-specific and all-purpose jurisdiction as still governing law.
Limits Perkins v. Benguet Consol. Mining Co. (342 U. S. 437)
Treats Perkins as an exceptional, narrow precedent rather than a broad model for finding a corporation 'at home' elsewhere.
Limits Pennoyer v. Neff (95 U. S. 714)
Describes Pennoyer's strict territorial approach to jurisdiction as long superseded by more flexible modern doctrine.