Second Circuit Says Not All Businesses Are Subject To Conn. Court Jurisdiction

In the 2014 case Daimler AG v. Bauman, the U.S. Supreme Court held that a state has general personal jurisdiction over only those corporations that incorporate or maintain a principal place of business in the state, or otherwise have such “substantial, continuous, and systematic contacts” that the corporation is “essentially at home” in the state.

So what about companies that register to transact business and appoint an agent for service of process in Connecticut, but are incorporated and maintain their principal place of business elsewhere? Do such registrations constitute voluntary “consent” to Connecticut’s exercise of general personal jurisdiction over the corporations, such that Bauman is inapplicable? Not according to the U.S. Court of Appeals for the Second Circuit. In an important recent decision, Brown v. Lockheed Martin, the Second Circuit disagreed with the Connecticut Appellate Court on the point, and “construe[d] Connecticut’s registration statute and appointment of agent provisions not to require registrant corporations that have appointed agents for service of process to submit to the general jurisdiction of Connecticut courts.”