14 January 2014

Law in Plain English: DaimlerChrysler AG v. Bauman

This is one in a series of posts designed to describe court decisions in plain English. For more detail and background on the legal issues, see the link to the case below. For similar posts, click here.

SCOTUSblogDaimlerChrysler AG v. Bauman

News Coverage:
Argument: Oct 15 2013 (Aud.)

Background: A group of Argentinians sued DaimlerChrysler Aktiengesellschaft (DCAG) in federal court in California under the  Alien Tort Statute (ATS) and the Torture Victims Protection Act of 1991 (TVPA). They alleged that that one of DCAG's subsidiaries, Mercedes-Benz Argentina (MBA), collaborated with Argentinian state security forces to kidnap, detain, torture, and kill the plaintiffs and/or their relatives during Argentina's "Dirty War." The District Court dismissed the case for lack of jurisdiction, but the Ninth Circuit reversed, finding that DCAG was subject to personal jurisdiction in California through because of its (indirect) corporate subsidiary Mercedes-Benz USA (MBUSA is a subsidiary of DaimlerChrysler North America Holding Corporation, which itself is a subsidiary of DCAG).

Issue: The question before the Court 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.

Holding: In a 9-0 decision, the Supreme Court ruled that Daimler is not amenable to suit in California for injuries allegedly caused by conduct of Mercedes-Benz Argentina that took place entirely outside the United States. As a result, the claims of the Argentinians fail because the Court does not have jurisdiction to hear the case.
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