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Daimler AG v. Bauman

United States Supreme Court
571 U.S. 117 (2014)

Written by Sean Carroll, JD

Facts

Barbara Bauman and other Argentinians (the Argentinians) (plaintiffs) sued DaimlerChrysler AG (Daimler) (defendant) in federal district court in California. Daimler was a German company that was headquartered in and manufactured Mercedes-Benz vehicles in Germany. The Argentinians alleged that Daimler’s Argentinian subsidiary, Mercedes-Benz Argentina (MBA), collaborated with Argentinian forces to kidnap, torture, and kill MBA workers in Argentina during a war. The workers and their relatives sued Daimler, seeking to hold Daimler vicariously liable for MBA’s conduct. Daimler moved to dismiss, arguing that the California district court lacked personal jurisdiction over Daimler. The Argentinians countered that the district court had general personal jurisdiction because Daimler’s US subsidiary, Mercedes-Benz USA, LLC (MBUSA), had substantial contacts with California. MBUSA, a Delaware corporation with its principal place of business in New Jersey, purchased vehicles from Daimler and imported them to the United States. MBUSA, as the exclusive US Mercedes-Benz distributor, sold Daimler vehicles in all 50 states. It had multiple offices in California. The district court granted Daimler’s motion to dismiss, concluding that personal jurisdiction was lacking. The Ninth Circuit reversed. The United States Supreme Court granted certiorari.

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Holding and Reasoning (Ginsburg, J.)

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