Goodyear Dunlop Tires Operations, S. A. v. Brown, 564 U.S. 915 (2011), was a United States Supreme Court case in which the Court held that the connection between Goodyear and its subsidiaries with the state of North Carolina was not strong enough to establish general personal jurisdiction over the companies.[1]
| Goodyear Dunlop Tires Operations, S. A. v. Brown | |
|---|---|
 | |
| Argued January 11, 2011 Decided June 27, 2011 | |
| Full case name | Goodyear Dunlop Tires Operations, S. A., et al., Petitioners v. Edgar D. Brown, et ux., Co-Administrators of the Estate of Julian David Brown, et al. |
| Docket no. | 10-76 |
| Citations | 564 U.S. 915 (more) 131 S. Ct. 2846; 180 L. Ed. 2d 796 |
| Argument | Oral argument |
| Case history | |
| Prior | denial of motion to dismiss affirmed sub nom. Brown v. Meter, 199 N.C. App. 50, 681 S.E.2d 382 (2009); review denied, 364 N.C. 128, 695 S.E.2d 756 (2010); cert. granted, 561 U.S. 1058 (2010). |
| Holding | |
| The connection between Goodyear and its subsidiaries with the state of North Carolina was not strong enough to establish jurisdiction over the companies. | |
| Court membership | |
| |
| Case opinion | |
| Majority | Ginsburg, joined by unanimous |
| Laws applied | |
| U.S. Const. amend. XIV | |
Fact and Procedural History
editTwo 13-year-old boys from North Carolina died as a result of a bus accident outside of Paris.[2] The parents of the boys believed the accident was due to a defective tire manufactured by a foreign subsidiary of Goodyear Tire and Rubber Company and sued for damages in a North Carolina state court.[3] The foreign subsidiaries asserted that the North Carolina courts lacked jurisdiction over them and moved to dismiss. The North Carolina trial court denied the motion and the North Carolina Court of Appeals affirmed.[4]
Opinion
editAs the claim did not arise in the forum state of North Carolina and none of the type of tires that caused the accident made it to North Carolina, the court cannot exercise specific jurisdiction over the defendants. Additionally, as only a small proportion of the subsidiaries’ products were distributed in North Carolina, and the subsidiaries did not systematically or persistently conduct business there as to be essentially at home there, the court cannot exercise general jurisdiction over all claims against the defendant.
Result
editThe Supreme Court reversed, holding that the foreign subsidiaries lacked a significant connection to North Carolina to warrant general personal jurisdiction.
References
edit- ^ Goodyear Dunlop Tires Operations, S. A. v. Brown United States Supreme Court, Opinion p. 3, "A connection so limited between the forum and the foreign corporation, we hold, is an inadequate basis for the exercise of general jurisdiction. Such a connection does not establish the “continuous and systematic” affiliation necessary to empower North Carolina courts to entertain claims unrelated to the foreign corporation’s contacts with the State."
- ^ Brown v. Meter Archived 2011-05-16 at the Wayback Machine North Carolina Court of Appeals, Opinion p. 3, "Matthew Helms and Julian Brown (Decedents), two thirteen-year-old soccer players who resided in North Carolina, died from injuries suffered in a bus wreck on 18 April 2004 outside Paris, France. Decedents were traveling to Charles de Gaulle Airport in preparation for returning to North Carolina at the time of the accident."
- ^ Brown v. Meter Archived 2011-05-16 at the Wayback Machine North Carolina Court of Appeals, Opinion p. 3, "Plaintiffs sought relief from a series of Goodyear affiliates, including Goodyear France, Goodyear Luxembourg, and Goodyear Turkey on a number of theories arising from an alleged negligent “design, construction, testing, and inspection” of and a failure to warn about alleged latent defects in the Goodyear Regional tire in question."
- ^ Brown v. Meter Archived 2011-05-16 at the Wayback Machine North Carolina Court of Appeals, Opinion p. 4, "On 1 May 2008, the trial court entered an order denying Defendants’ dismissal motions." Opinion, p. 29, "The trial court did not err in exercising general jurisdiction over Defendants and denying their dismissal motion... the trial court’s order should be, and hereby is, affirmed."
External links
edit- Text of Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915 (2011) is available from: Google Scholar Justia Oyez (oral argument audio) Supreme Court (slip opinion) (archived)