JONES DAY ON GOODYEAR SUPREME COURT CASE
04 Jul, 2011
U.S. Supreme Court rules for Goodyear in personal jurisdiction case
On June 27, 2011, the United States Supreme Court decided a significant personal jurisdiction case, ruling in favour of Jones Day clients Goodyear Dunlop Tires Operations, SA; Goodyear Lastikleri T.A.S.; and Goodyear Dunlop Tires France, SA (affiliates of Goodyear Tire & Rubber Co.) in Goodyear Dunlop Tires Operations, S.A. v. Brown. The Court held that the North Carolina state courts did not obtain ‘general’ personal jurisdiction over the Goodyear affiliates for causes of action unrelated to their activity in the state simply because a portion of their products had been sold by other Goodyear entities in North Carolina.
The Goodyear affiliates manufactured and distributed tyres primarily for use in Europe and Asia. After North Carolina teenagers died in a bus accident while travelling in Paris, their parents brought wrongful-death actions in North Carolina state court against, among others, the Goodyear affiliates who had manufactured and distributed the bus’s tyres. The tyres at issue had never been distributed in North Carolina. The North Carolina Court of Appeals exercised general personal jurisdiction over the Goodyear entities on the ground that a small percentage of their products—unrelated to the tire on the ill-fated bus—had been sold by other Goodyear entities in North Carolina. Jones Day successfully petitioned for certiorari in the U.S. Supreme Court, and briefed and argued the case on the merits.
In a unanimous decision, the U.S. Supreme Court reversed the state court. It held that the sales in North Carolina did not suffice to create the substantial connection between the state and the Goodyear affiliates necessary for general jurisdiction, explaining that ‘the paradigm forum for the exercise of general jurisdiction is the individual’s domicile; for a corporation, it is an equivalent place, one in which the corporation is fairly regarded as at home’.
Jones Day partner Meir Feder (New York) argued the case. The Jones Day team also included partner Glen Nager (Washington) and associates Eric Murphy (Columbus) and Rajeev Muttreja (New York).