--- title: "Daimler AG v. Bauman" type: Landmark Case source: https://casebriefly.com/landmark-cases/daimler-ag-v-bauman --- # Daimler AG v. Bauman Daimler dramatically narrowed general jurisdiction over corporations by holding that a corporation is subject to general jurisdiction only where it is 'at home,' which is typically limited to its state of incorporation and its principal place of business. The decision rejected the notion that systematic and continuous contacts alone are sufficient for general jurisdiction. ## Citation 571 U.S. 117 (2014) ## Year 2014 ## Court Supreme Court of the United States ## Facts Argentine residents sued Daimler AG, a German corporation, in the Northern District of California, alleging that Daimler's Argentine subsidiary, Mercedes-Benz Argentina, collaborated with state security forces during Argentina's Dirty War to kidnap, detain, torture, and kill certain workers at a plant in Argentina. The plaintiffs attempted to establish general jurisdiction over Daimler in California based on the California contacts of Daimler's U.S. subsidiary, Mercedes-Benz USA (MBUSA), which was headquartered in New Jersey but had significant operations in California. ## Procedural History The district court dismissed for lack of jurisdiction. The Ninth Circuit reversed, holding that MBUSA's contacts could be attributed to Daimler under an agency theory and that those contacts were sufficient for general jurisdiction. The Supreme Court granted certiorari. ## Issue Whether a foreign corporation is subject to general personal jurisdiction in a state where it has substantial but not primary business operations, based on the in-state activities of a subsidiary. ## Holding The Supreme Court held that California could not exercise general jurisdiction over Daimler. 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. For a corporation, the paradigm bases for general jurisdiction are the place of incorporation and the principal place of business. Even assuming MBUSA's contacts were attributable to Daimler, California was not Daimler's home. ## Reasoning Justice Ginsburg wrote that International Shoe's 'continuous and systematic' language, when applied to general jurisdiction, must be understood as requiring contacts so substantial that the defendant is essentially at home in the forum. The Court emphasized that general jurisdiction subjects a defendant to suit on any claim, regardless of where the underlying events occurred, and therefore the standard should be demanding. Allowing general jurisdiction based merely on substantial business operations would mean that a corporation doing extensive business nationwide could be sued in every state on every claim, which would be 'unacceptably grasping.' The paradigm forums for general jurisdiction are incorporation and principal place of business, with an exceptional case possible in unusual circumstances. ## Dissent Justice Sotomayor concurred in the judgment but disagreed with the majority's 'at home' test. She argued that the majority's approach was too restrictive and that the Court should have resolved the case by holding that the exercise of jurisdiction would be unreasonable, rather than by narrowing the general jurisdiction test itself. ## Impact Daimler fundamentally reshaped general jurisdiction by effectively limiting it to a corporation's place of incorporation and principal place of business in all but exceptional cases. This decision significantly reduced the forums in which plaintiffs can bring suit against multinational corporations and prompted a wave of jurisdictional challenges. The case also raised questions about whether the 'at home' test would extend to individuals and about what the 'exceptional case' exception might encompass. ## Key Quotes - A court may assert general jurisdiction over foreign (sister-state or foreign-country) corporations to hear any and all claims against them when their affiliations with the State are so 'continuous and systematic' as to render them essentially at home in the forum State. - With respect to a corporation, the place of incorporation and principal place of business are 'paradig[m] ... bases for general jurisdiction.' - A corporation that operates in many places can scarcely be deemed at home in all of them. Otherwise, 'at home' would be synonymous with 'doing business' tests framed before specific jurisdiction evolved in the United States. ## Related Cases - international-shoe-v-washington - bristol-myers-squibb-v-superior-court - ford-motor-co-v-montana - burnham-v-superior-court - goodyear-dunlop-tires-v-brown ## Exam Relevance Daimler is heavily tested on civil procedure exams for general jurisdiction questions. Students must be able to apply the 'at home' test and identify the paradigm bases for general jurisdiction. Exam questions often present corporations with substantial operations in multiple states and ask whether general jurisdiction exists. Students should also be prepared to discuss the 'exceptional case' dicta. ## Study Tips - Memorize the two paradigm bases for corporate general jurisdiction: state of incorporation and principal place of business. - Understand why the Court rejected the 'doing business' test and adopted the more restrictive 'at home' standard. - Be prepared to distinguish Daimler's general jurisdiction analysis from the specific jurisdiction analysis in Bristol-Myers Squibb and Ford Motor Co. - Consider the practical implications: after Daimler, large corporations are typically subject to general jurisdiction in only two states. ## Doctrine Established At Home Test for General Jurisdiction --- Source: [Daimler AG v. Bauman — CaseBriefly](https://casebriefly.com/landmark-cases/daimler-ag-v-bauman)