Goodyear Dunlop Tires Operations, S.A. v. Brown

Facts

A bus accident in Paris that took the lives of two 13-year-old boys from North Carolina. Attributing the accident to a defective tire manufactured in Turkey at the plant of a foreign subsidiary of The Goodyear Tire and Rubber Company (D1), the boys' parents, Brown (P) commenced an action for damages in a North Carolina state court; they named as defendants D1, an Ohio corporation, and three of its subsidiaries, organized and operating, respectively, in Turkey, France, and Luxembourg (D). D1 had plants in North Carolina and regularly engaged in commercial activity there, did not contest the North Carolina court's jurisdiction over it; Ds maintained that North Carolina lacked adjudicatory authority over them. Ds moved to dismiss the claims against them for want of personal jurisdiction. The trial court denied the motion, and the North Carolina Court of Appeals affirmed. The Court of Appeals confined its analysis to 'general rather than specific jurisdiction,' which the court recognized required a 'higher threshold' showing: A defendant must have 'continuous and systematic contacts' with the forum. That threshold was crossed, the court determined, when D placed their tires 'in the stream of interstate commerce without any limitation on the extent to which those tires could be sold in North Carolina.' Ds 'took no affirmative action to cause tires which they had manufactured to be shipped into North Carolina.' The tires reached North Carolina as a consequence of a 'highly-organized distribution process' involving other D subsidiaries. Ds made 'no attempt to keep these tires from reaching the North Carolina market.' The very tire involved in the accident, the court observed, conformed to tire standards established by the U.S. Department of Transportation and bore markings required for sale in the United States. The Supreme Court granted certiorari. 

Issues

Rule of Law

Holding and Decision

Legal Analysis

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