Mallory v. Norfolk Southern Railway Co.
Overview
Overview
The Supreme Court addressed whether the Fourteenth Amendment's Due Process Clause permits a state court to exercise personal jurisdiction over a defendant corporation that is not incorporated in the state and does not have its principal place of business there, based solely on the corporation's registration to do business in the state. Which under that state's law constitutes consent to general personal jurisdiction in all cases, not just those arising from the defendant's local activities.
The Facts
Facts
Robert Mallory, a Virginia resident and former Norfolk Southern employee, developed cancer he attributed to his work-related asbestos exposure. He sued Norfolk Southern in Pennsylvania. Not where he worked or where his injury occurred, but where Norfolk Southern was registered to do business. Pennsylvania's registration statute provided that registering to do business constituted consent to general personal jurisdiction. Norfolk Southern argued this violated the Fourteenth Amendment's due process limits on personal jurisdiction established in Daimler AG v. Bauman (2014).
The Issue
Issue
Whether the Fourteenth Amendment's Due Process Clause is violated when a state court exercises general personal jurisdiction over a foreign corporation based solely on the corporation's registration to conduct business in the state, which under that state's law constitutes consent to general jurisdiction over all claims.
The Rules
Rule
The Fourteenth Amendment's due process protections limit a court's exercise of personal jurisdiction to cases where the defendant has 'minimum contacts' with the forum state such that requiring the defendant to answer claims there does not offend 'traditional notions of fair play and substantial justice.' Daimler AG v. Bauman (2014) held that general jurisdiction exists only in a corporation's state of incorporation and principal place of business. Consent to jurisdiction via registration statutes predates the modern due process framework.
The Application
Analysis
Although Daimler AG v. Bauman established strict limits on general jurisdiction based on a corporation's presence or activities, the Court found that consent to jurisdiction operates as an independent constitutional basis outside that framework. Norfolk Southern's registration to do business in Pennsylvania under a state statute requiring such registration to constitute consent to general jurisdiction satisfied the minimum contacts standard, because the defendant's voluntary choice to register in the state provided the necessary constitutional anchor. The Court therefore upheld Pennsylvania's exercise of general jurisdiction over Norfolk Southern even though Mallory's asbestos-related injury arose from his employment outside Pennsylvania and had no connection to the defendant's operations there.
The Conclusion
Conclusion
Decided June 27, 2023. The Court held 5-4 that Pennsylvania's registration-based consent jurisdiction statute does not violate the Fourteenth Amendment's due process limits. The majority held that Daimler did not eliminate consent as an independent basis for personal jurisdiction; corporations that register to do business in a state may constitutionally be subject to general jurisdiction there under a valid consent statute. The ruling created significant incentive for forum shopping through strategic registration.
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