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Every first-year student of civil procedure learns that a company must submit to general personal jurisdiction ' all-purpose jurisdiction over any and all disputes ' in a forum where the company conducts “continuous and systematic” business activities. See International Shoe Co. v. Washington, 326 U.S. 310, 317 (1945). This standard is easy enough to recite, but explaining it and applying it in a coherent manner has long been a more difficult task. Happily, with its recent decision in Daimler AG v. Bauman, the Supreme Court has now brought at least some measure of clarity and predictability to the notoriously vague standards governing general jurisdiction. This article provides an overview of the Court's general-jurisdiction doctrine, discusses the recent decision in Bauman, and assesses the likely impact of the decision going forward.
The State of the Doctrine Before Bauman
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