U.S. Supreme Court Sharply Limits General Jurisdiction Over Corporate Defendants

On January 14, 2014, the U.S. Supreme Court issued Daimler AG v. Bauman, a unanimous decision reaffirming that the Due Process Clause permits a court to assert general jurisdiction over a corporation only if that corporation is “at home” within the forum state, and signaling that a corporate defendant is likely to be “at home” (and subject to general jurisdiction) only where the corporation is incorporated or has its principal place of business. In so doing, Bauman simplifies the general jurisdictional inquiry and substantially narrows the circumstances under which general jurisdiction will lie, explicitly rejecting more expansive theories of general jurisdiction that had acquired some currency in the lower federal courts. Bauman carries significant implications for how corporate defendants should evaluate their amenability to the general jurisdiction of U.S. courts.