Goodyear Dunlop Tires Operations, S.A. v. Brown explained

Litigants:Goodyear Dunlop Tires Operations, S. A. v. Brown
Arguedate:January 11
Argueyear:2011
Decidedate:June 27
Decideyear:2011
Fullname:Goodyear Dunlop Tires Operations, S. A., et al., Petitioners v. Edgar D. Brown, et ux., Co-Administrators of the Estate of Julian David Brown, et al.
Docket:10-76
Oralargument:https://www.oyez.org/cases/2010-2019/2010/2010_10_76/argument
Usvol:564
Uspage:915
Parallelcitations:131 S. Ct. 2846; 180 L. Ed. 2d 796
Prior:denial of motion to dismiss affirmed sub nom. Brown v. Meter, 199 N.C. App. 50, 681 S.E.2d 382 (2009); review denied, 364 N.C. 128, 695 S.E.2d 756 (2010); cert. granted, .
Holding:The connection between Goodyear and its subsidiaries with the state of North Carolina was not strong enough to establish jurisdiction over the companies.
Majority:Ginsburg
Joinmajority:unanimous
Lawsapplied:U.S. Const. amend. XIV

Goodyear Dunlop Tires Operations, S. A. v. Brown, 564 U.S. 915 (2011), was a United States Supreme Court case in which the Court held that the connection between Goodyear and its subsidiaries with the state of North Carolina was not strong enough to establish general personal jurisdiction over the companies.[1]

Fact and Procedural History

Two 13-year-old boys from North Carolina died as a result of a bus accident outside of Paris.[2] The parents of the boys believed the accident was due to a defective tire manufactured by a foreign subsidiary of Goodyear Tire and Rubber Company and sued for damages in a North Carolina state court.[3] The foreign subsidiaries asserted that the North Carolina courts lacked jurisdiction over them and moved to dismiss. The North Carolina trial court denied the motion and the North Carolina Court of Appeals affirmed.[4]

Opinion

As the claim did not arise in the forum state of North Carolina and none of the type of tires that caused the accident made it to North Carolina, the court cannot exercise specific jurisdiction over the defendants. Additionally, as only a small proportion of the subsidiaries’ products were distributed in North Carolina, and the subsidiaries did not systematically or persistently conduct business there as to be essentially at home there, the court cannot exercise general jurisdiction over all claims against the defendant.

Result

The Supreme Court reversed, holding that the foreign subsidiaries lacked a significant connection to North Carolina to warrant general personal jurisdiction.

Notes and References

  1. https://www.supremecourt.gov/opinions/10pdf/10-76.pdf Goodyear Dunlop Tires Operations, S. A. v. Brown
  2. http://www.aoc.state.nc.us/www/public/coa/opinions/2009/pdf/080944-1.pdf Brown v. Meter
  3. http://www.aoc.state.nc.us/www/public/coa/opinions/2009/pdf/080944-1.pdf Brown v. Meter
  4. http://www.aoc.state.nc.us/www/public/coa/opinions/2009/pdf/080944-1.pdf Brown v. Meter