564 U.S. 915 (2011) (U.S. Supreme Court)
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.
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.
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.