1. Why didn’t the parents of the boys in this case initiate their lawsuit against the foreign subsidiaries of Goodyear USA in a French court?
2. Does this decision mean that the boys’ parents are without any legal recourse against Goodyear’s foreign subsidiaries
3. The parent company in this case is Goodyear USA, an Ohio with its principal place of business in the state of Ohio. Would the courts in North Carolina have personal jurisdiction over Goodyear USA in this case? Why or why not?
4. What if the executives of Goodyear’s foreign subsidiaries had attended a business retreat in North Carolina? Would their presence in North Carolina allow a state court to exercise personal jurisdiction over the foreign subsidiaries in this case?
Two 13-year-old boys from the state of North Carolina, Matthew Helms and Julian Brown, had traveled to France to participate in a soccer tournament. The two boys were involved in a bus wreck outside Paris on their way back to the airport and died from injuries suffered in the accident. The parents of the boys believed the accident was due to a defective tire manufactured by a foreign subsidiary of the Goodyear Tire and Rubber Company (Goodyear USA) and sued the parent company and three of its foreign subsidiaries in a state court in North Carolina. Goodyear USA did not challenge personal jurisdiction, but the foreign subsidiaries argued that the North Carolina courts lacked jurisdiction over them and moved to dismiss the complaint for lack of personal jurisdiction. The trial court denied the motion, and the North Carolina Court of Appeals affirmed the trial court’s decision in favor of Brown, ruling that a small percentage of tires manufactured by the foreign subsidiaries had entered the North Carolina market and that was sufficient minimum contacts. The Good year foreign subsidiaries then appealed to the U.S. Supreme Court.
The U.S. Supreme Court reversed the decision of the appellate court and ruled in favor of Goodyear. The Court concluded that specific jurisdiction was lacking in this case because the foreign subsidiaries’ contacts with North Carolina were too limited. In addition, the Court also ruled that general jurisdiction over the foreign subsidiaries did not exist either. Specifically, the Court held that general jurisdiction is available to hold a answerable for all claims within a state only if the corporation’s contacts with the forum state are so continuous and systemic as to render the “at home” in the forum state.
Continuous and Systematic Contacts “ The Due Process Clause of the Fourteenth Amendment sets the outer boundaries of a state tribunal’s authority to proceed against [an-out-of-state] defendant. The canonical opinion in this area remains International Shoe,326 U.S. 310, in which we held that a State may authorize its courts to exercise personal jurisdiction over an out-of-state defendant if the defendant has ‘certain minimum contacts with [the State] such that the maintenance of the suit does not offend “traditional notions of fair play and substantial justice.”’ . . . North Carolina is not a forum in which it would be permissible to subject petitioners to [personal] jurisdiction. [The foreign subsidiaries of Goodyear USA] are in no sense at home in North Carolina. Their attenuated connections to the State . . . fall far short of ‘the continuous and systematic general business contacts’ necessary to empower North Carolina to entertain suit against them on claims unrelated to anything that connects them to the State.’”
