Are foreign subsidiaries of a United States parent corporation amenable to suit in state court on claims unrelated to any activity of the subsidiaries in the forum State?
Civil Procedure I, Pages 133–135
⭐Goodyear Dunlop Tires Operations, S.A. v. Brown
Supreme Court of the United States, 2011
Facts:
A bus accident outside Paris that killed two boys from North Carolina was attributed to faulty tires made in Turkey by a subsidiary of Goodyear USA. The boys' parents sued Goodyear USA, and Ohio corporation, and three subsidiaries in a North Carolina state court. Goodyear USA accepted this jurisdiction, but its subsidiaries did not.
Procedural History:
State supreme court ruled they had jurisdiction.
Issue:
Plaintiff's Argument:
Defendant intentionally placed goods into the stream of commerce which reached North Carolina, giving them minimum contacts. Goods also harmed plaintiffs' sons in France.
Rule:
The goods brought into the forum state by the stream of commerce must also be the source of injury in question if it is the only contact with the state for specific jurisdiction.
Reasoning:
Defendant did not have relevant contacts to the state, as the bad tires where sold in France.
Holding:
No, the activity in the forum state must have been related to the claim. Judgment reversed.
