Also known as: at home · general jurisdiction · Daimler
Written by attorneys · grounded in primary & secondary sources — see below
A standard for asserting general personal jurisdiction over a corporation that requires the corporation's affiliations with the forum state to be so constant and pervasive as to render it essentially at home there. The standard is satisfied only in the place of incorporation or principal place of business except in truly exceptional cases.
Evergreen Bank, incorporated and headquartered in Delaware, sells millions of dollars of financial products each year in Michigan through local branches. A Michigan resident injured in an accident abroad sues the bank in Michigan federal court on an unrelated claim. The court dismisses for lack of general jurisdiction because the bank's Michigan sales do not render it at home there.
Emerald Enterprises, a Delaware corporation with its principal place of business in New York, maintains a large design center and testing facility in Ohio. Plaintiffs injured in foreign accidents sue the company in Ohio for claims having no connection to that state. The court grants dismissal because the Ohio facility does not make the company at home there.
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Edgewater Capital, incorporated and headquartered in California, sells its investment products through dealers in every state including Texas. Investors harmed by products purchased and used only in Europe sue the firm in Texas. The court rejects general jurisdiction because ongoing Texas sales alone do not render the firm at home there.
Horizon Manufacturing, incorporated and headquartered in Nevada, operates a distribution warehouse in Florida. A Florida plaintiff injured by a product purchased in Georgia sues Horizon in Florida on an unrelated claim. The court dismisses for lack of general jurisdiction because the Florida warehouse does not render Horizon at home there.
Summit Industries, incorporated and headquartered in Delaware, sells products nationwide including in Illinois. An Illinois resident injured abroad by a Summit product sues in Illinois on an unrelated claim. The court dismisses because continuous Illinois sales do not make Summit at home there.
Pinnacle Motors, incorporated and headquartered in Michigan, maintains authorized dealers throughout California. A California buyer injured by a vehicle purchased in Arizona sues Pinnacle in California on an unrelated claim. The court dismisses because the dealership network does not render Pinnacle at home in California.
A corporation is essentially at home in its state of incorporation and its principal place of business. Only in exceptional cases will general jurisdiction exist elsewhere.
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No. Substantial or even extensive business operations in a state do not by themselves support general jurisdiction over unrelated claims.
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For individuals, general jurisdiction typically requires domicile in the forum state rather than the corporate at-home formulation.
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…under the attachment laws of Ohio, and laid down the principle of assuming that all had been rightly done by a court having general jurisdiction of the subject-matter. In Cooper v. Smith , 25 Iowa, 269, it is said, that where no process is served on the defendant, nor property attached, nor garnishee charged, nor appearance…