Supreme Court to hear Civil Procedure Cases

Supreme Court to hear Civil Procedure Cases

Current and former United States law students will no doubt fondly recall the Supreme Court case of International Shoe Co. v. Washington, 326 U.S. 310 (1945), from their first-year Civil Procedure classes.  Students of Civil Procedure know that the jurisdiction of state courts in the United States covers the state in which the court sits, and as far beyond those bounds as may be consistent with the Due Process Clause of the United States Constitution.[1]  Federal district courts will draw the limits of their own jurisdiction from the laws governing the courts of the state where they sit.[2]  Courts may exercise specific jurisdiction over a corporate defendant in cases where “the activities of the corporation [in the state] have not only been continuous and systematic, but also give rise to the liabilities sued on, even though no consent to be sued or authorization to an agent to accept service of process has been given.”[3]  A court’s general jurisdiction may be exercised over a defendant in a forum for any purpose, due to the defendant being domiciled within the forum,[4] or when a defendant’s “affiliations with the State are so ‘continuous and systematic’ as to render them essentially at home in the forum State.”[5]

In the 2014 United States Supreme Court case of Daimler AG v. Bauman,[6] Argentine plaintiffs sought to apply United States law in an action against Daimler, the German auto manufacturer, for actions that allegedly took place in Argentina.[7]  Briefly, the plaintiffs invoked the California district court’s general jurisdiction over Daimler, basing this on the allegedly extensive activities of a Daimler subsidiary in California.[8]  In reversing a ruling of the Ninth Circuit Court of Appeals holding that the California district court could exercise general jurisdiction over Daimler[9], the Supreme Court held that the proper inquiry was not whether Daimler’s California activities were “continuous and systematic,” but rather whether Daimler’s affiliations with California were so “continuous and systematic” “‘as to render [it] essentially at home in the forum State.’”[10]

Two up-coming Supreme Court cases will likely give further consideration to these jurisdictional distinctions.  The first case is BNSF Railway Co. v. Tyrrell.  This case concerns the Federal Employers’ Liability Act,[11] which allows injured railroad workers or their survivors to bring suit against their employer.[12]  The FELA also specifies that jurisdiction is proper where “the defendant shall be doing business at the time of commencing such action.”[13]  The issue in Tyrrell is stated as:

Whether a state court may decline to follow the Supreme Court’s decision in Daimler AG v. Bauman, which held that the due process clause forbids a state court from exercising general personal jurisdiction over a defendant that is not at home in the forum state, in a suit against an American defendant under the Federal Employers’ Liability Act.

The second case is Bristol Myers Squibb v. Superior Court of California, San Francisco County.  The case involves a dispute over a drug manufactured by Bristol Myers Squibb Co.  The issue in this case is stated as

Whether a plaintiff’s claims arise out of or relate to a defendant’s forum activities when there is no causal link between the defendant’s forum contacts and the plaintiff’s claims – that is, where the plaintiff’s claims would be exactly the same even if the defendant had no forum contacts.

These matters will be argued before the Supreme Court on April 25, 2017.  Both of these cases have the potential to be extremely important in analyzing future jurisdictional disputes.  Furthermore, Neil Gorsuch, recently confirmed as the Supreme Court’s newest Associate Justice, may also be taking part in these decisions.  Future litigators at Villanova Law should be very interested in these outcomes.

[1] See Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915, 923, (2011).

[2] See Daimler AG v. Bauman, 134 S.Ct. 746, 753 (2014) (citing Fed. Rule Civ. Proc. 4(k)(1)(A)).

[3] International Shoe Co. v. Washington, 326 U.S. 310, 317(1945).

[4] See Goodyear, 564 U.S., at 924.

[5] See Goodyear, 564 U.S., at 919 (citing International Shoe, 326 U.S., at 317).

[6] Daimler AG v. Bauman, 571 U.S. ___ (2014), 134 S.Ct. 746 (2014).

[7] Id.

[8] See Daimler, 134 S.Ct., at 751.

[9] See Bauman v. DaimlerChrysler Corp., 644 F.3d 909 (2011).

[10] See Daimler, 134 S.Ct., at 761 (citing Goodyear, 564 U.S., at 919; see also International Shoe, 326 U.S., at 317).

[11] See 45 U.S.C. §§ 51-60.

[12] See 45 U.S.C. § 51.

[13] 45 U.S.C. § 56.

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