Daimler AG v. Bauman, 571 U.S. 117 (2014)
Daimler AG v. Bauman is the Supreme Court's modern lodestar on general (all-purpose) personal jurisdiction over corporations.
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.
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.