Parties: Petitioner; Goodyear Dunlop Tires Operations, S. A., et al. Respondent; Brown Et Ux., Co-Administrators of the Estate of Brown, et al
Procedural History/ Case Nature: The respondent filed a case in North Carolina State Court, against the petitioners. The cause of action had occurred in France. The petitioners argued against the jurisdiction of the North Carolina court, at the trial court. The court of first instance held that it had jurisdiction over this matter. The petitioners appealed the case in the North Carolina Court of Appeal, where the court affirmed that it had general jurisdiction over the matter.
Facts of the Case: The respondents’ sons had died in a bus accident in France. They alleged that the accident was as a result of tire failure. The respondents filed the case against Goodyear USA, and Goodyear USA subsidiaries, operating and organized, in Turkey, Luxembourg, and France. The Petitioners ’products, tires, are not manufactured primarily for USA market but, for Asia and Europe markets. The tires are also different in design and size from tires commonly sold in the U.S. The Petitioners are not legally registered to conduct business in North Carolina; have not employed, no bank accounts, no place of business; do not advertise ,manufacture or design their products in the State. They also do not solicit business, sell or ship tires to North Carolina clients. Nevertheless, a considerable portion of their tires were in circulation in North Carolina, distribution done by other Goodyear USA affiliates.
Issues: Whether the North California courts had jurisdiction over the matter? Whether a company not based in USA could be subject to USA laws/jurisdiction?
Legal Rules: The law that would guide the court include: the Fourteen Amendment’s clause which deals with due process. The decision of the court in the case; International Shoe Co. v. Washington, which considered the jurisdiction of the court in matters of defendants/parties who are out-of-state; the case of HelicopterosNacionales de Colombia, S.A. v. Hall which deals with specific and general jurisdiction; the case of Perkins v. Benguet Consol Mining Co., , which deals with systematic and continuous of unrelated contacts in general jurisdiction; and the case of World-Wide Volkswagen Corp. v. Woodson which deals with specific jurisdiction as a result of flow of products into the forum jurisdiction.
Analysis/Application: The Court of Appeal had the jurisdiction since the Fourteen Amendment sets out the due process clause on outer boundaries of a state tribunal authority. Moreover, where an activity in the state is by a corporation, jurisdiction could be asserted, provided the activity is systematic and continuous, and contributed to the suit. The activity may be occasional or single acts. However, only with respect to matters related to the forum connections. The two categories give rise to specific jurisdiction. In addition, where the corporate activities are of a justifiable nature for a suit against the corporate, cause of action originating from interactions entirely dissimilar from those activities, the jurisdiction would be so grounded, that it would be characterized as general jurisdiction.
Therefore, the activities of the Petitioners were deficient of the kind of systematic and continuous general business interactions necessary to permit North Carolina to allow a suit against them, on matters that are not related to any activity that connects them to the State. Measured against, North Carolina would not subject petitioners to general jurisdiction.
Conclusion: Reversed. The court unanimously reversed the Certiorari that was earlier granted by lower courts.
Goodyear Dunlop Tires Operations, S. A., et al. V. Brown Et Ux., Co-Administrators of the Estate of Brown, et al., 681 S.E.2d 382., http://www.law.cornell.edu/supct/html/10-76.ZS.html
International Shoe Co. v.Washington, 326 U.S. 310., http://caselaw.lp.findlaw.com/scripts/getcase.pl?court=us&vol=326&invol=310
Perkins v. Benguet Consol. Mining Co., 342 U.S. 437., http://supreme.justia.com/cases/federal/us/342/437/