Term: 2013
Docket: 11-965
Daimlerchrysler Ag v. Bauman
- Pro
11-965 DAIMLERCHRYSLER AG V. BAUMAN DECISION BELOW: 644 F.3d 909 CERT. GRANTED 4/22/2013 QUESTION PRESENTED: Daimler AG is a German public stock company that does not manufacture or sell products, own property, or employ workers in the United States. The Ninth Circuit nevertheless held that Daimler AG is subject to general personal jurisdiction in California--and can therefore be sued in the State for alleged human-rights violations committed in Argentina by an Argentine subsidiary against Argentine residents--because it has a different, indirect subsidiary that distributes Daimler AG-manufactured vehicles in California. It is undisputed that Daimler AG and its U.S. subsidiary adhere to all the legal requirements necessary to maintain their separate corporate identities. The question presented is whether it violates due process for a court to exercise general personal jurisdiction over a foreign corporation based solely on the fact that an indirect corporate subsidiary performs services on behalf of the defendant in the forum State. LOWER COURT CASE NUMBER: 07-15386
In DaimlerChrysler AG v. Bauman (2013), the U.S. Supreme Court ruled that a court in California could not hear a case against DaimlerChrysler, a German company, brought by Argentinian residents for human rights violations allegedly committed in Argentina during the 1970s. The plaintiffs claimed that Mercedes-Benz Argentina, a subsidiary of DaimlerChrysler, collaborated with state security forces to kidnap, detain and torture employees at its Buenos Aires plant who were suspected union agitators. However, the Supreme Court held that even if Mercedes-Benz USA was subject to jurisdiction in California due to its extensive contacts there as an importer and seller of cars manufactured by DaimlerChrysler abroad; this did not mean that its parent company also had sufficient minimum contacts with California for it to be sued there over actions unrelated to those activities.
In the DaimlerChrysler AG v. Bauman case, Justice Sotomayor was the only justice to dissent from the majority opinion. She agreed with the Court's decision that Daimler could not be sued in California for injuries allegedly caused by its Argentinian subsidiary during Argentina’s “Dirty War.” However, she disagreed with how they reached this conclusion. Instead of focusing on whether or not Daimler had sufficient contacts with California (the approach taken by the majority), Sotomayor argued that it would have been more appropriate to consider whether exercising jurisdiction over Daimler in this particular case would be reasonable and fair under traditional notions of fair play and substantial justice. In her view, a corporation should expect to face legal action anywhere it purposefully avails itself of conducting activities if those actions cause harm, regardless of where they occur.
