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Major Supreme Court Cases on Constitutional Amenability to Suit

(Constitutional Personal Jurisdiction)


Intl Shoe (1945)

Jurisdiction upheld.
in order to subject a defendant to a judgment
in personam, if he be not present within the
territory of the forum, he have certain
minimum contacts with it such that the
maintenance of the suit does not offend
traditional notions of fair play and substantial
justice.
Whether due process is satisfied must depend
rather upon the quality and nature of the
activity in relation to the fair and orderly
administration of the laws which it was the
purpose of the due process clause to insure.

McGee
(1957)

v.

Intl

to the extent that a corporation exercises the


privilege of conducting activities within a state,
it enjoys the benefits and protection of the laws
of that state. The exercise of that privilege may
give rise to obligations, and, so far as those
obligations arise out of or are connected with
the activities within the state, a procedure
which requires the corporation
to respond to a suit brought to enforce them
can, in most instances, hardly be said to be
undue.
Life Jurisdiction upheld. Specific jurisdiction: a
single act can be sufficient
Ca held to have manifest interest in providing
redress to one of its residents

Hanson v. Denckla (1958) No jurisdiction. But test expanded to introduce


purposeful availment. To satisfy due process,
the defendant must have purposefully availed
itself of privilege of conducting activities
within the forum
WWV v. Woodson (1980) No jurisdiction. Unilateral activity by plaintiff
cant establish jurisdiction. As for stream of
commerce issue in that product liability case,
court said that a defendant purposefully avails
itself of forum when it places goods into the
stream of commerce with the expectation that
they will be purchased by consumers within
the forum State and a consumer is injured
there
Helicopteros
v.
Hall No Jurisdiction. GJ case.
(1984)
Calder v. Jones (1985)
Jurisdiction upheld. Broad reading of
jurisdictional power in this libel case. Effects
test: jurisdiction proper because CA was focus
point both of the story and of the harm
suffered by the plaintiff. Jurisdiction proper
over defendants in California based on the
effects of their Florida conduct in California.
Burger
King
v. Jurisdiction upheld. And expansive reading of
Rudzewicz (1985)
test by Brennans opinion.
"the foreseeability that is critical to due process
analysis . . . is that the defendant's conduct and
connection with the forum State are such that
he should reasonably anticipate being haled
into court there
The unilateral activity of those who claim
some relationship with a nonresident defendant
cannot satisfy the requirement of contact with

the forum State. The application of that rule


will vary with the quality and nature of the
defendant's activity, but it is essential in each
case that there be some act by which the
defendant purposefully avails itself of the
privilege of conducting activities within the
forum State, thus invoking the benefits and
protections of its laws."
Jurisdiction is proper, however, where the
contacts proximately result from actions by the
defendant himself that create a "substantial
connection" with the forum State. Thus where
the defendant "deliberately" has engaged in
significant activities within a State, or has
created "continuing obligations" between
himself and residents of the forum, he
manifestly has availed himself of the privilege
of conducting business there, and because his
activities are shielded by "the benefits and
protections" of the forum's laws it is
presumptively not unreasonable to require him
to submit to the burdens of litigation in that
forum as well.

where individuals "purposefully derive benefit"


from their interstate activities, it may well be
unfair to allow them to escape having to
account in other States for consequences that
arise proximately from such activities

By requiring that individuals have "fair


warning that a particular activity may subject

[them] to the jurisdiction of a foreign


sovereign, the Due Process Clause "gives a
degree of predictability to the legal system that
allows potential defendants to structure their
primary conduct with some minimum
assurance as to where that conduct will and
will not render them liable to suit,"
Finally- signaled two step analysis

Asahi Metal v. Superior No jurisdiction. Split (no majority) on first step


Court (1987)
(minimum contacts). Majority found second
step (reasonableness) not met.
Burnham v. Superior Jurisdiction upheld, with split on court as to
Court (1990)
why.
Goodyear
v.
Brown No jurisdiction. General jurisdiction case.
(2011)
Essentially at home
McIntyre. v. Nicastro No jurisdiction. Still unresolved stream of
(2011)
commerce issues for us to discuss.
Daimler AG v. Bauman
No jurisdiction. General jurisdiction case.
(2014)
Further discussion of essentially at home
standard
[a] court may assert general jurisdiction over
foreign (sister-state or foreign-country)
corporations to hear any and all claims against
them when their affiliations with the State are
so continuous and systematic as to render
them essentially at home in the forum State.
Goodyear

For an individual, the paradigm forum for the


exercise of general jurisdiction is the
individuals domicile; for a corporation, it is an
equivalent place, one in which the corporation
is fairly regarded as at home.
With respect to a corporation, the place of
incorporation and principal place of business
are paradig[m] . . . bases for general jurisdiction. Those affiliations have the virtue of
being uniquethat is, each ordinarily indicates
only one placeas well as easily ascertainable
These bases afford plaintiffs recourse to at least
one clear and certain forum in which a
corporate defendant may be sued on any and
all claims.
If Daimlers California activities sufficed to
allow adjudication of this Argentina-rooted
case in California, the same global reach would
presumably be available in every other State in
which MBUSAs sales are sizable. Such
exorbitant exercises of all-purpose jurisdiction
would scarcely permit out-of-state defendants
to structure their primary conduct with some
minimum assurance as to where that conduct
will and will not render them liable to suit.
20To clarify in light of JUSTICE
SOTOMAYORs opinion concurring in the
judgment, the general jurisdiction inquiry does
not focu[s] solely on the magnitude of the
defendants in-state contacts. Post, at 8.
General jurisdiction instead calls for an

appraisal of a corporations activities in their


entirety, nationwide and worldwide.

Walden v. Fiore (2014)

19We do not foreclose the possibility that in an


exceptional case, see, e.g., Perkins, described
supra, at 1012, and n. 8, a corporations
operations in a forum other than its formal
place of incorporation or principal place of
business may be so substantial and of such a
nature as to render the corporation at home in
that State.
No jurisdiction.
specific jurisdiction over a nonresident
defendant focuses on the relationship among
the defendant, the forum, and the litigation.
For a State to exercise jurisdiction consistent
with due process, the defendants suit-related
conduct must create a substantial connection
with the forum State.
First, the relationship must arise out of
contacts that the defendant himself creates
with the forum State
Second, our minimum contacts analysis
looks to the defendants contacts with the
forum State itself, not the defendants contacts
with persons who reside there.
To be sure, a defendants contacts with the
forum State may be intertwined with his
transactions or interactions with the plaintiff or
other parties. But a defendants relationship

with a plaintiff or third party, standing alone, is


an insufficient basis for jurisdiction.
A forum States exercise of jurisdiction over
an out-of-state intentional tortfeasor must be
based on intentional conduct by the defendant
that creates the necessary contacts with the
forum.
The crux of Calder was that the reputationbased effects of the alleged libel connected
the defendants to California, not just to the
plaintiff.

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