Daimler Ag v. Bauman

134 S.Ct. 746 (2014)

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Nature of the Case

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Facts

This case concerns the authority of a court in the United States to entertain a claim brought by foreign plaintiffs against a foreign defendant based on events occurring entirely outside the United States. The litigation commenced Bauman (Ps), twenty-two Argentinian residents, filed a complaint in the District Court for the Northern District of California against D. D is headquartered in Stuttgart, manufactures Mercedes-Benz vehicles in Germany. Ps allege that during Argentina’s 1976-1983 “Dirty War,” D's subsidiary collaborated with state security forces to kidnap, detain, torture, and kill certain workers, among them, Ps or persons closely related to Ps. Jurisdiction in California was based on contacts of Mercedes-Benz USA, LLC (MBUSA), a subsidiary of D incorporated in Delaware with its principal place of business in New Jersey. MBUSA distributes D manufactured vehicles to independent dealerships throughout the United States, including California. Ps invoke general jurisdiction. Ps contend that D may be sued in California on any and all claims against it, wherever in the world, the claims may arise. D moved to dismiss the action for want of personal jurisdiction. D moved to dismiss the action for want of personal jurisdiction. MBUSA is a Delaware limited liability corporation. MBUSA’s principal place of business is in New Jersey, MBUSA has multiple California facilities, including a regional office in Costa Mesa, a Vehicle Preparation Center in Carson, and a Classic Center in Irvine. Over 10% of all sales of new vehicles in the United States take place in California, and MBUSA’s California sales account for 2.4% of D’s worldwide sales. A General Distributor Agreement establishes MBUSA as an “independent contractor” that “buys and sells vehicles . . . as an independent business for [its] own account.” The agreement “does not make it a general or special agent, partner, joint venturer or employee of D. The District Court granted D’s motion to dismiss. The Ninth Circuit affirmed the District Court’s judgment. D appealed.