Doe v. Unocal Corp.
United States Court of Appeals for the Ninth Circuit
248 F.3d 915 (2001)
- Written by Rose VanHofwegen, JD
Facts
Burmese farmers (plaintiffs) sued in California federal court alleging Unocal Corporation, French corporation Total S.A., and the corporations’ top executives (defendants) violated international human rights while building the Yadana gas pipeline. Total had no contacts in the United States other than listing stock on American exchanges and promoting its sale and moved to dismiss for lack of personal jurisdiction. However, Total had subsidiaries in California or with substantial California contacts that selected and acquired holding companies in Total’s petrochemical and chemical niche markets. The farmers showed Total was an active parent corporation directly involved in decision making about its subsidiaries’ holdings. However, Total observed all corporate formalities necessary to maintain corporate separateness. The district court concluded it lacked personal jurisdiction over Total and dismissed the claims against it. The farmers appealed.
Rule of Law
Issue
Holding and Reasoning (Per curiam)
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