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Daimler, AG v. Bauman | 571 U.S. 117 (2014)
When an atrocity or other outrageous violence occurs, we instinctively want to give the victims a chance to demand justice from their persecutors. But that desire is tempered against the due-process rights afforded to foreign defendants. An example of this conflict resulted in the United States Supreme Court’s 2014 decision in Daimler, AG versus Bauman.
Twenty-one Argentinian residents, including Barbara Bauman, sued German carmaker DaimlerChrysler in federal district court in California. The plaintiffs alleged that DaimlerChrysler subsidiary Mercedes-Benz Argentina collaborated with security forces during Argentina’s civil war to kidnap, torture, and kill Mercedes-Benz Argentina personnel.
While this case worked its way through the courts, DaimlerChrysler became Daimler, AG, so we’ll just call it Daimler. New Jersey-based Mercedes-Benz USA, or MBUSA, was also a Daimler subsidiary. MBUSA bought Mercedes-Benz cars in Germany, imported them into the United States, and sold them to dealers nationwide, including in California. MBUSA also had a regional headquarters in California.
The plaintiffs only sued Daimler. But they argued that MBUSA was subject to general jurisdiction in California and that it had acted as Daimler’s agent. The plaintiffs reasoned that California could therefore exercise jurisdiction over Daimler regarding the events that occurred during the war.
The district court granted Daimler’s motion to dismiss the case for lack of jurisdiction. The United States Court of Appeals for the Ninth Circuit initially affirmed, but on reconsideration, it reversed the district court and reinstated the plaintiffs’ claim. Daimler then sought review in the United States Supreme Court.
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