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Corporate Entities Litigation

General Personal Jurisdiction in Aviation Cases After Daimler

Daimler's impact is seen in a growing number of decisions where courts have dismissed actions because they found that the corporate defendants' business connections to the jurisdictions were not sufficient to justify general jurisdiction.

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In its 2014 landmark decision Daimler AG v. Bauman, 134 S. Ct. 746 (2014), the U.S. Supreme Court held that a corporation is only subject to general jurisdiction when it has such constant and pervasive affiliations with the state where the suit is brought that it can be deemed “at home” in that state. The Supreme Court held that a corporation’s “paradigm” homes are its place of incorporation and principal place of business and noted that “in an exceptional case” a corporation’s operations elsewhere “may be so substantial and of such a nature as to render the corporation at home in that State.” Id. at 760-61 & n.19.

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